UK Updates the Cosmetics Regulation Annexes: Technical Overview of SI 2026/23

On 15 January 2026, the UK Government adopted Statutory Instrument SI 2026/23, introducing amendments to the Annexes of the UK Cosmetics Regulation (UKCR).

From a regulatory perspective, this amendment is part of the UK’s ongoing process of maintaining alignment with technical updates introduced under Regulation (EC) No 1223/2009, while implementing them through domestic legislation.

Below is our technical analysis of the key implications for cosmetic manufacturers and Responsible Persons operating in the UK market.

Table of contents

1. Update to Annex II – Prohibited Substances

2. Technical implications

3. Amendment to Annex V – Formaldehyde-Releasing Preservatives

4. What this means in practice?

5. Transitional Periods

UK Updates the Cosmetics Regulation Annexes: Technical Overview of SI 2026/23

Update to Annex II – Prohibited Substances

The amendment introduces new entries into Annex II (List of substances prohibited in cosmetic products), including:

• 4-methylbenzylidene camphor (4-MBC)

• Trimethylbenzoyl Diphenylphosphine Oxide (TPO)

• 15 additional substances classified as CMR

Technical implications

From a safety assessment standpoint:

Ingredients newly classified as CMR under UK CLP can no longer be used in cosmetic formulations unless specific derogations apply (which, in this case, do not).

Safety Assessors must review existing CPSRs where these substances may be present as:

• intentional ingredients

• impurities

• residuals

• degradation products

Particular attention should be paid to UV filter systems and raw material specifications where 4-MBC may historically have been used.

Amendment to Annex V – Formaldehyde-Releasing Preservatives

The preamble to Annex V has been updated, strengthening the labelling requirements related to formaldehyde-releasing preservatives.

What this means in practice?

• The warning statement requirements have been clarified.

• Responsible Persons must verify:

  • Free formaldehyde levels in the finished product

  • Correct triggering of warning statements

  • Alignment between analytical data and label wording

  
  

This amendment reinforces enforcement expectations rather than introducing an entirely new concept. However, it increases the compliance risk for products relying on older labelling templates.

Transitional Periods

The SI establishes staggered compliance deadlines:

• Mid-2026 (July–August) → Deadline for placing non-compliant products on the UK market

• Early 2027 (January–February) → Deadline for making non-compliant products unavailable (off-shelf compliance)

For companies managing UK and EU portfolios simultaneously, stock management planning is critical to avoid stranded inventory.

If your company requires a technical screening of UK formulas or assistance updating CPSRs and labelling documentation, our regulatory team can support a structured compliance transition plan ahead of the 2026 deadlines.