EU Cosmetics Regulation Update
On October 22, 2026, the European Parliament adopted its first-reading position on the Chemicals Omnibus VI package. The text would revise CMR transition periods, retain pre-market notification for certain cosmetic nanomaterials, and introduce online sales disclosure requirements. It is not yet in force: the procedure is awaiting the Council's first-reading position, and no entry-into-force date has been confirmed.
The package also covers the EU Classification, Labelling and Packaging (CLP) Regulation and the EU Fertilising Products Regulation.
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CMR Substance Derogations and Phase-Out Timelines
The Commission's initial proposal would have excluded substances classified as CMR solely on the basis of oral or inhalation exposure from the general prohibition under Regulation (EC) No 1223/2009 on cosmetic products. The Parliament's position does not retain this provision. Companies should not assume that classification based on these exposure routes, on its own, removes the need to assess the prohibition or any applicable derogation requirements.
The Parliament's position revises the transition periods. Where no derogation request is submitted, it shortens the periods proposed by the Commission from 12 and 24 months to 6 and 12 months. It also specifies timelines for cases where a derogation is refused:
| Scenario | Applicable CMR Categories | End of Placing-on-the-Market Period | End of Making-Available-on-the-Market Period |
|---|---|---|---|
| No derogation request submitted | Categories 1A, 1B and 2 | 6 months | 12 months |
| Derogation request submitted but refused due to SCCS safety concerns | Categories 1A, 1B and 2 | 3 months | 9 months |
| SCCS finds the use safe, but the derogation is refused because a suitable alternative is available | Categories 1A and 1B | 24 months | 36 months |
The 24- and 36-month periods apply only if an up-to-date Cosmetic Product Safety Report (CPSR) remains available at all times. The transition periods run from the date the relevant amendment to Annex II of the Cosmetics Regulation enters into force. They provide time for product phase-out and do not constitute a derogation from the CMR prohibition.
For CMR Category 1A and 1B substances, the Parliament's position removes the proposed food-safety condition. A derogation would require that no suitable alternative be available and that the Scientific Committee on Consumer Safety (SCCS) has assessed the substance as safe for the relevant cosmetic use.
The assessment of alternatives would consider whether they are safe for human health, reduce overall risk, provide an equivalent function and comparable performance, and are technically and economically feasible. The Commission, in consultation with the European Chemicals Agency (ECHA), is to develop guidance on the analysis of alternatives within one year after the amending regulation enters into force.
Nanomaterial Notification Requirements
The Commission's proposal would have removed the additional notification requirement for cosmetic products containing nanomaterials. The Parliament's position retains the responsible person's obligation to notify the Commission electronically before placing on the market products using nanomaterials not listed in Annex III of the Cosmetics Regulation. It removes the current requirement to notify at least six months in advance.
The notification would include information such as the nanomaterial's identity and specifications, estimated annual quantity in the cosmetic product, toxicological data, safety data for the relevant product category, and reasonably foreseeable exposure conditions. The general product notification under Article 13, submitted through the Cosmetic Products Notification Portal (CPNP), would continue to apply separately.
New Information Disclosure Requirements for Distance Sales
The Commission's proposal did not amend the Cosmetics Regulation's labelling provisions to address distance sales. The Parliament's position would require online offers for cosmetic products to display specified information clearly and visibly, including:
The responsible person's name or registered name and address
The country of origin for imported products
The product's nominal content
Any special precautions for use
The product's function
The list of ingredients
The responsible person information requirement is relevant to companies' existing EU Responsible Person arrangements. Under the Parliament's position, the distance-sales disclosure requirement would apply 12 months after the amending regulation enters into force.
The position also addresses ingredient nomenclature and the treatment of certain natural complex substances. It would require ingredient names to follow internationally recognised nomenclature, such as INCI, or generally accepted nomenclature where no common name exists. A natural complex substance would not automatically trigger the CMR prohibition solely because it contains a CMR-classified constituent, if the substance as a whole is not classified as CMR. The SCCS would assess the constituent's safety in relevant cosmetic uses.
Impact & Priority Actions for Cosmetics Businesses
Priority risk: CMR product phase-out
The most time-sensitive issue is the potential phase-out of cosmetics containing CMR substances. Under the Parliament's position, companies could have only six months to stop placing affected products on the market if no derogation request is submitted; the period could fall to three months if the SCCS identifies safety concerns.
While the amendments are not yet in force, companies should:
Screen formulas for CMR Category 1A, 1B and 2 substances and identify affected products.
Assess whether a derogation may be justified and begin compiling safety and alternatives evidence. A request would need to be submitted no later than three months after the relevant amendment to Part 3 of Annex VI to the CLP Regulation enters into force.
Prepare phase-out or reformulation scenarios for affected products. If relying on the 24- or 36-month transition period, keep an up-to-date CPSR available.
The transition-period countdowns have not started; companies should confirm the final regulation and applicable dates once the legislative process is complete.
How REACH24H Can Help
REACH24H supports companies with EU cosmetics market access and ongoing compliance, including ingredient and formula reviews, CPSR and Product Information File preparation, Responsible Person arrangements, CPNP notification, and label and claims reviews. Our team can help assess potential portfolio impacts and develop a compliance plan based on the final regulation.
Review Your EU Cosmetics Compliance Needs
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