The Cosmetic Products (Restriction of Chemical Substances) Regulations 2025

Protecting Consumer Health: The regulations aim to safeguard consumers from potential harm by limiting the concentration of methyl salicylate in various cosmetic products based on scientific evidence of its safety. This is supported by the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products and aligns with the EU's Regulation (EC) No 1223/2009.

Harmonizing with EU Regulations: The regulations bring UK legislation into line with EU standards for cosmetic safety, ensuring consistency across the market and facilitating trade. This is implemented through amending Annex 3 of Regulation (EC) No 1223/2009, providing a legal framework.

Risk-Based Approach: The regulations establish different permissible levels of methyl salicylate depending on the specific cosmetic product type, reflecting varied exposure and risk profiles. The varying concentration limits in the schedule are based on the scientific evidence and reflect the differing risk of use.

Gradual Implementation: A transitional period allows businesses to adjust to the new regulations without immediate disruption, mitigating potential economic impacts. The March 2026 deadline facilitates a smooth transition for businesses managing existing stock.

Economic Burden on Businesses: The regulations may impose costs on businesses to reformulate products and manage outdated stock, particularly small and medium-sized enterprises (SMEs). This includes reformulating products and disposing of existing stock that does not meet the new standards, affecting profit margins.

Regulatory Complexity: The different concentration limits for varied cosmetic product types can create complexity for businesses, increasing compliance costs and potential for error. This is especially true given the numerous product categories identified within these regulations.

Potential for Overregulation: The restrictions, while scientifically informed, might be criticized as overly cautious or disproportionate, potentially affecting the availability or affordability of certain cosmetic products. The lack of significant predicted impact may be questioned, requiring more thorough future analysis.

Limited Impact Assessment: The absence of a full impact assessment may raise concerns about the thoroughness of the regulatory process and its potential unforeseen consequences. Further study may yield a broader understanding relevant to both the economic impacts on businesses and the public health effects on consumers.