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Apr 16, 2026 - Cosmetics

Substance bans and their impact on the safety report of cosmetics

According to Regulation (EC) No 1223/2009, the preparation of a safety report is mandatory for each cosmetic product. It is important that this report is continuously updated and adjusted when the regulations change. An adjustment is usually necessary when substances are banned or restricted.

The ban or restriction of substances by setting maximum quantities can occur in two ways:

Option 1: by directly amending Regulation (EC) No 1223/2009

The basis for this is usually an opinion prepared by the EU's Scientific Committee (SCCS: Scientific Committee on Consumer Safety)
The adjustment is made through an amendment regulation
There are transition periods of sometimes several months or years to allow the sale of cosmetic products

Option 2: through an amendment in the chemical law

This adjustment comes from chemical law (REACH) and primarily affects not only cosmetics but also other product categories
In the case of a restriction or ban, there are generally no transition periods
A ban is therefore immediate, so special caution is required to avoid the continued sale of products containing the corresponding substance

Currently, in terms of a revision and overhaul of cosmetic law, there are considerations to also use corresponding transition periods for Option 2. This would give manufacturers more time to implement the corresponding re-regulation.

In addition, there are considerations to dissolve the SCCS as such or to integrate it into the respective structures of ECHA (European Chemicals Agency).

We keep you informed about all regulatory changes. Please feel free to contact us at any time if you have questions!

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