Nov 11, 2025
from CIRS
by CIRS
On 31 October 2025, the United Kingdom submitted notification G/TBT/N/GBR/107 to the World Trade Organization (WTO), announcing the draft of the Cosmetic Products (Restriction of Chemical Substances) Regulations 2026 and proposing amendments to the Regulation (EC) No 1223/2009. The main revisions include the prohibition of 4-Methylbenzylidene Camphor in cosmetic products, the ban of 16 CMR substances, and the lowering of the labelling threshold for formaldehyde releasing substances. The deadline for comments on the draft is 30 December 2025.
Key Revisions
1. Prohibition of the Use of 4-Methylbenzylidene Camphor in Cosmetic Products
4-Methylbenzylidene Camphor (4-MBC) (CAS Nos. 36861-47-9, 38102-62-4) is currently listed in Annex VI (List of UV filters Allowed in Cosmetic Products) of the UK Regulation No. 1223/2009, with a maximum concentration in ready for use preparation of 4% in cosmetic products.
On May, 2025, Scientific Advisory Group of Chemical Safety of Non-food and Non-medicinal Consumer Products (SAG-GS) issued opinion on 4-Methylbenzylidene Camphor (4-MBC) as a UV Filter in Cosmetic Product. The Members noted concerns with regard to the safety of 4-MBC including the lack of a robust genotoxicity and reproductive/developmental toxicity package and concerns with regard to endocrine disruption properties. The Members were not able to derive a safe level for use of 4-MBC in cosmetics. Given the limited data package available for review, and potential concerns for genotoxicity and endocrine disruption, the SAG-CS could not conclude that 4-MBC is safe for use in sunscreen products and other cosmetic products.
Based on the above assessment opinion, the UK intends to prohibit the use of 4-Methylbenzylidene Camphor in cosmetic products by removing it from Annex VI and including it in Annex II (List of Substances Prohibited in Cosmetic Products) of the Regulation (EC) No 1223/2009.
No.
Chemical Name/INN
CAS No.
EC No.
1744
3-(4-Methylbenzylidene)-d1
camphor/Enzacamene
38102-62-4/36861-47-9
253-242-6
- Transitional Provision: Cosmetic products containing 4-Methylbenzylidene Camphor shall not be placed on the market in England, Wales, and Scotland from 15 July 2026, and shall not be made available on the market in these regions from 15 January 2027.
2. Prohibition of 16 CMR Substances
The UK intends to include the following 16 substances, classified as CMR (Carcinogenic, Mutagenic, or Reprotoxic) category 1B or 2, in Annex II of the Regulation (EC) No 1223/2009. These substances will be prohibited for use in cosmetic products.
No.
Chemical Name/INN
CAS No.
EC No.
1745
Diphenyl(2,4,6-trimethylbenzoyl)phosphineoxide
75980-60-8
278-355-8
1746
clothianidin (ISO); (E)-1-(2-chloro-1,3-thiazol-5-ylmethyl)-3
-methyl-2-nitroguanidine
210880-92-5
433-460-1
1747
Dimethyl propylphosphonate
18755-43-6
242-555-3
1748
Dibutyltin maleate
78-04-6
201-077-5
1749
Dibutyltin oxide
818-08-6
212-449-1
1750
2,2’, 6,6’-tetrabromo-4,4’-isopropylidenediphenol; tetrabromobisphenol-A
79-94-7
201-236-9
1751
1,4-Benzenediamine, N,N’-mixed Ph and tolylderivs.
68953-84-4
273-227-8
1752
4-Methylimidazole
822-36-6
212-497-3
1753
Acetone Oxime
127-06-0
204-820-1
1754
Benthiavalicarb isopropyl (ISO); isopropyl [(S)-1-{[(R)-1-(6-
fluoro-1,3-benzothiazol-2-yl)ethyl]carbamoyl}-2-methylpropyl]carbamate
177406-68-7
1755
2,3-epoxypropyl neodecanoate
26761-45-5
247-979-2
1756
Multi-walled carbon tubes (synthetic graphite in tubular shape) with a geometric tube diameter range≥ 30 nm to 3:1, including
MultiWalled Carbon Nanotubes, MWC(N)T
1757
7-oxabicyclo[4.1.0]hept-3-ylmethyl 7-oxabicyclo [4.1.0] heptan- 3-carboxylate
2386-87-0
219-207-4
1758
2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4- (morpholin-4-yl)phenyl]butan-1-one
119344-86-4
438-340-0
1759
- metolachlor (ISO); 2-chloro-N-(2-ethyl-6-methylphenyl)-N -[(2S)-1-methoxypropan-2-yl]acetamide; (R a S a)-2-chloro-N
-(6-ethyl-o-tolyl )-N-[(1S)-2-methoxy-1-methylethyl]acetamide
[contains 80-100 % 2-chloro-N-(2-ethyl-6-met hylphenyl)-N
-[(2S)-1-methox-ypropan-2-yl]ace tamide and 0-20 % 2-chloro
-N-(2-ethyl-6-met hylphenyl)-N-[(2R)-1-methoxypropan-2
-yl]ace tamide]
87392-12-9
1760
Trimethyl borate
121-43-7
204-468-9
- Transitional Provision: Cosmetic products containing any of the above CMR substances shall not be placed on the market in England, Wales, and Scotland from 15 August 2026, and shall not be made available on the market in these regions from 15 February 2027.
3. Lower Labelling Threshold for Formaldehyde Releasing Substances
On May, 2025, SAG-CS issued opinion on formaldehyde releasing substances. Members agreed that a threshold of labelling of formaldehyde releasing preservatives of 10 mg/kg (10 ppm) or 0.001% would be appropriate to protect consumers based on current scientific evidence when using leave-on or rinse-off products.
Based on the above assessment opinion, for the text in paragraph 2 substitute of Annex V (List of Preservatives Allowed in Cosmetic Products), it would be replaced into the following: “All finished products containing substances in this Annex and which release formaldehyde must be labelled with the warning ‘releases formaldehyde’ where the concentration of formaldehyde in the finished product exceeds 0.001%.”.
- Transitional Provision: Cosmetic products containing formaldehyde releasing substances listed in the Annex shall not be placed on the market in England, Wales and Scotland from 15 July 2026, and shall not be made available on the market in these regions from 15 January 2027.
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Further Information
https://members.wto.org/crnattachments/2025/TBT/GBR/25_07356_00_e.pdf
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