Regulation (EU) 2026/909: New Restrictions for Cosmetic Ingredients, Fragrances, Hair Dyes, Aluminium, Zinc and DHHB
Commission Regulation (EU) 2026/909, published in the Official Journal of the European Union on 28 April 2026, amends several annexes of Regulation (EC) No 1223/2009 on cosmetic products.
The new regulation introduces updated restrictions, prohibitions and conditions of use for several substances used in cosmetic products. In particular, the changes affect fragrance allergens, hair dyes, aluminium-containing ingredients, water-soluble zinc salts, preservatives and UV filters.
As a result, cosmetic companies, manufacturers, importers and brand owners should carefully review their formulations, technical documentation and product labelling to ensure compliance with the new requirements.
Which substances are affected by Regulation (EU) 2026/909?
The regulation introduces changes concerning several cosmetic ingredients, including:
- Benzyl Salicylate;
- Triphenyl Phosphate;
- Ammonium Silver Zinc Aluminium Silicate;
- aluminium-containing ingredients;
- water-soluble zinc salts;
- Acetylated Vetiver Oil;
- Citral;
- HC Blue No. 18;
- HC Red No. 18;
- HC Yellow No. 16;
- Hydroxypropyl-p-phenylenediamine and its dihydrochloride salt;
- Diethylamino Hydroxybenzoyl Hexyl Benzoate, also known as DHHB.
Triphenyl Phosphate: New Prohibition in Cosmetic Products
One of the key changes concerns Triphenyl Phosphate, which is added to Annex II of Regulation (EC) No 1223/2009, the list of substances prohibited in cosmetic products.
This substance was used in cosmetic products as a plasticiser, mainly to soften or increase the flexibility of certain synthetic polymers. However, the Scientific Committee on Consumer Safety could not conclude on its safety, due to insufficient information to fully assess the substance and exclude its potential genotoxicity.
Transitional deadlines:
- from 1 January 2027, cosmetic products containing Triphenyl Phosphate and not complying with the new restrictions shall not be placed on the EU market;
- from 1 July 2028, such products shall not be made available on the EU market.
Benzyl Salicylate: New Maximum Concentration Limits
Benzyl Salicylate was already regulated as a fragrance allergen subject to labelling requirements above specific thresholds. Regulation (EU) 2026/909 now introduces maximum concentration limits depending on the type of cosmetic product.
| Product category | Maximum concentration |
|---|---|
| Fragrances | 4% |
| Rinse-off skin and hair products, excluding shower gels/bath products | 0.5% |
| Shower gels/bath products | 1.3% |
| Leave-on skin and hair products, non-spray/non-aerosol, excluding body lotions | 0.5% |
| Leave-on hair/beard products, spray/aerosol | 0.5% |
| Body lotions | 0.7% |
| Face make-up and make-up removers | 0.2% |
| Oral care products | 0.004% |
| Deodorant products, spray/aerosol | 0.91% |
Furthermore, Benzyl Salicylate must still be indicated in the list of ingredients when its concentration exceeds:
- 0.001% in leave-on products;
- 0.01% in rinse-off products.
Citral: Updated Limits by Product Category
Citral, already known as a fragrance allergen, is now subject to more detailed maximum concentration limits according to the cosmetic product category.
| Product category | Maximum concentration |
|---|---|
| Lip products | 0.11% |
| Deodorants and antiperspirants | 0.032% |
| Eye products, face make-up and make-up removers | 0.65% |
| Fragrances | 0.6% |
| Leave-on skin products and nail products | 0.15% |
| Oral care products | 0.35% |
| Leave-on hair/beard products | 1.2% |
| Rinse-off skin and hair/beard products | 1.2% |
| Leave-on products for the anogenital area, including baby wipes and intimate wipes | 0.063% |
In addition, Citral must be declared in the list of ingredients when its concentration exceeds:
- 0.001% in leave-on products;
- 0.01% in rinse-off products.
Aluminium-Containing Ingredients: New Limits in Cosmetics
The regulation introduces a new entry in Annex III for aluminium-containing ingredients, with limits expressed as percentage of aluminium.
This applies to aluminium-containing ingredients that are not already specifically regulated under other entries of the annexes to the Cosmetics Regulation.
| Product category | Maximum concentration in Al |
|---|---|
| Non-aerosol antiperspirants or deodorants | 7.73% |
| Aerosol antiperspirants or deodorants | 3.24% |
| Toothpastes | 3.18% |
| Lip products | 14.62% |
| Rinse-off body and face products | 0.89% |
| Soap bars | 4% |
| Rinse-off hair/beard products | 7.14% |
| Leave-on hair/beard products that may lead to lung exposure by inhalation | 0.15% |
| Make-up products, excluding lip products, eyeliner, eyeshadow, nail polish and mascara | 23% |
| Eyeliner | 15.76% |
| Eyeshadow | 43.31% |
| Nail polish | 3.61% |
| Mascara | 3.13% |
| Leave-on face products, excluding specific make-up products | 10.59% |
| Leave-on hand products | 0.86% |
| Powder talc | 2.0% |
Moreover, certain product categories are subject to additional conditions or warnings, especially where inhalation exposure may occur.
Water-Soluble Zinc Salts: New Conditions for Toothpastes and Mouthwashes
Regulation (EU) 2026/909 also updates the conditions of use for water-soluble zinc salts, including Zinc Acetate, Zinc Chloride, Zinc Gluconate, Zinc Glutamate, Zinc Citrate and Zinc Sulphate.
These changes are particularly relevant for oral care products.
| Product category | Maximum concentration |
|---|---|
| Toothpastes intended for users over one year of age | 1% in zinc |
| Toothpastes intended for children between six months and one year of age | 0.72% in zinc |
| Mouthwashes intended for users over six years of age | 0.1% in zinc |
| Other cosmetic products | 1% in zinc |
Therefore, companies marketing toothpastes, mouthwashes or other oral care products containing zinc salts should carefully verify the concentration and intended age group of use.
Acetylated Vetiver Oil: New Restrictions as a Fragrance Ingredient
Acetylated Vetiver Oil, used as a fragrance ingredient, is added to Annex III with specific limits depending on the product category.
| Product category | Maximum concentration |
|---|---|
| Fragrances | 0.9% |
| Deodorants | 0.05% |
| Make-up products | 0.05% |
| Leave-on products, excluding fragrances, deodorants and make-up | 0.1% |
| Rinse-off products | 0.2% |
The raw material must also be stabilised with 1% alpha-tocopherol.
Ammonium Silver Zinc Aluminium Silicate: Authorised as a Preservative under Specific Conditions
The regulation also amends the status of Ammonium Silver Zinc Aluminium Silicate. This substance is now authorised as a preservative under specific conditions.
It may be used up to 1% in:
- spray deodorants;
- powder foundations.
The silver content in the substance must not exceed 2.5%.
This change may be relevant for manufacturers using alternative preservative systems, especially in a regulatory context where the number of available preservatives is increasingly limited.
Hair Dyes: New Regulated Substances
Regulation (EU) 2026/909 introduces new entries in Annex III for certain hair dye substances, establishing maximum concentrations and labelling requirements.
HC Blue No. 18
HC Blue No. 18 is permitted:
- in oxidative hair dye products, with a maximum concentration applied to hair after mixing of 0.35%;
- in non-oxidative hair dye products, up to 0.35%.
Hydroxypropyl-p-phenylenediamine and Hydroxypropyl-p-phenylenediamine 2HCl
These substances are permitted in oxidative hair dye products, with a maximum concentration applied to hair after mixing of 2%.
HC Yellow No. 16
HC Yellow No. 16 is permitted:
- in oxidative hair dye products up to 1% after mixing;
- in non-oxidative hair dye products up to 1.5%.
HC Red No. 18
HC Red No. 18 is permitted:
- in oxidative hair dye products up to 1.5% after mixing;
- in non-oxidative hair dye products up to 0.5%.
For oxidative hair dye products, the usual warnings concerning allergic reactions, minimum age of use and temporary black henna tattoos must be included on the label.
DHHB: New Limit for the Impurity DnHexP
The UV filter Diethylamino Hydroxybenzoyl Hexyl Benzoate, known as DHHB, remains authorised in cosmetic products up to 10%.
However, Regulation (EU) 2026/909 introduces a new condition concerning the impurity di-n-hexyl phthalate, also referred to as DnHexP. This impurity, as an unavoidable trace in the DHHB substance, must not exceed 10 ppm.
Transitional deadlines for non-compliant DHHB-containing products:
- from 1 January 2027, cosmetic products containing non-compliant DHHB shall not be placed on the EU market;
- from 1 July 2028, such products shall not be made available on the EU market.
Main Deadlines to Remember
For many of the substances subject to new restrictions, the regulation provides a transitional period divided into two main stages.
| Date | Requirement |
|---|---|
| 1 January 2027 | Non-compliant cosmetic products shall no longer be placed on the EU market |
| 1 July 2028 | Non-compliant cosmetic products shall no longer be made available on the EU market |
Nevertheless, for certain substances, the final date for making products available on the market may differ. Therefore, companies should verify the applicable transitional provision for each specific substance.
What Should Cosmetic Companies Do?
Cosmetic companies should start reviewing their product portfolio as soon as possible, especially if they market products containing fragrances, hair dyes, UV filters, aluminium-containing ingredients, zinc salts or alternative preservative systems.
The recommended actions include:
- reviewing cosmetic formulations to identify the presence of the affected substances;
- checking concentrations of use against the new limits;
- requesting updated supplier documentation, especially for fragrances, DHHB, aluminium-containing ingredients and complex raw materials;
- updating the Product Information File, where necessary;
- reviewing the safety assessment in light of the new conditions of use;
- checking product labelling, including mandatory warnings and allergen declarations;
- planning possible reformulations;
- managing stock and sell-off periods to avoid non-compliant products remaining on the market after the applicable deadlines.
Conclusions
Regulation (EU) 2026/909 represents an important update to the European cosmetics regulatory framework. The changes affect substances used in a wide range of cosmetic products, including fragrances, deodorants, hair products, make-up, oral care products, sunscreens and products containing specific functional ingredients.
For companies, it is essential not to limit the assessment to a formal reading of the regulation. Instead, they should perform a technical review of formulations, raw materials, safety documentation and labelling.
A timely compliance review can help prevent regulatory issues, product withdrawals, market access problems and stock management difficulties.
Do You Need Support with Cosmetic Product Compliance?
We provide regulatory support to cosmetic companies, brand owners, importers and manufacturers for compliance with European cosmetic legislation.
Our services include:
- cosmetic formula review;
- assessment of restricted ingredients;
- label compliance check;
- Product Information File update;
- supplier documentation review;
- support for reformulation projects;
- regulatory assistance for placing cosmetic products on the EU market.
Contact us to assess your cosmetic products in light of Regulation (EU) 2026/909.