Regulation 2026/909, adopted on 27 April 2026 and published in the Official Journal of the European Union on 28 April 2026, amends Regulation (EC) No 1223/2009 in relation to cosmetic ingredients. Its purpose is not to completely rebuild the European cosmetics framework, but to update several annexes with new prohibitions, restrictions on use and technical conditions applicable to certain substances, in light of recent safety assessments. The Regulation entered into force 20 days after its publication, that is, on 18 May 2026.
The update affects ingredients used in very different categories, such as fragrances, preservatives, UV filters, mineral salts and hair dyes. In practice, this requires manufacturers, importers and brands to review formulations, concentrations, purity, technical documentation and, in some cases, also the market continuity strategy for certain products.
What changes with Regulation 2026/909
The Regulation affects a specific group of substances: Benzyl Salicylate, Triphenyl Phosphate, Ammonium Silver Zinc Aluminium Silicate, aluminium, 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, and DHHB. Not all of them are affected in the same way: some become prohibited, others are restricted to certain uses, concentrations or conditions, and others are updated due to specific safety or purity issues.
In other words, this is not a “general prohibition of cosmetic ingredients”, but a selective amendment to several annexes of Regulation 1223/2009. That means the regulatory impact must be analysed ingredient by ingredient, product by product and use by use, which is exactly the least entertaining and most necessary part.
Prohibitions of cosmetic ingredients
One of the clearest changes affects Triphenyl Phosphate. The Commission indicates that the SCCS was unable to conclude on its safety due to insufficient data for a complete assessment and to rule out possible genotoxicity. As a result, it has been added to the list of prohibited substances in Annex II. The text also sets transitional dates: from 1 January 2027, cosmetic products containing it and not complying with the new regulatory status may no longer be placed on the Union market, and from 1 July 2028 they may no longer be made available on the Union market.
This type of change requires more than simply reviewing a technical data sheet. If a substance is moved to Annex II, the practical consequence is usually the need to reformulate, progressively withdraw the product or manage stock within the transitional deadlines.
Restrictions under Regulation 2026/909 on concentrations and use
Other substances do not disappear entirely, but become subject to new restrictions. This is the case for Benzyl Salicylate, for which the SCCS concluded that its use can only be considered safe up to certain maximum concentrations. Therefore, its use is limited in Annex III to the levels considered safe.
The same applies to water-soluble zinc salts, for which the text sets maximum concentrations in toothpastes: up to 1% zinc for users over 1 year of age and 0.72% zinc for children between 6 months and 1 year. These restrictions are also subject to the general transitional timetable of 1 January 2027 for placing on the market and 1 July 2028 for making available on the market.
Substances such as Acetylated Vetiver Oil follow the same logic, with use restricted to the concentrations considered safe by the SCCS, including certain conditions for sprayable products with possible inhalation exposure.
Fragrances and sensitisation: special attention to Citral
Citral was already listed as a fragrance allergen in Annex III, but the new Regulation updates its regulatory treatment in the context of new safety evaluations. The text also recalls its classic declaration thresholds for consumer information: 0.001% in leave-on products and 0.01% in rinse-off products.
In this case, Regulation 2026/909 also introduces a peculiarity in the deadlines: some entries related to Citral are subject to a later date for making available on the market, so that certain non-compliant products may no longer continue to be marketed from 1 August 2028, instead of 1 July 2028, which applies more generally to other restricted substances.
This matters quite a lot, because a poor reading of the timeline may lead a company to plan everything around a single withdrawal date when, in reality, Regulation 2026/909 distinguishes between different situations.
Preservatives and substances that change status
One of the most striking changes affects Ammonium Silver Zinc Aluminium Silicate. The Regulation 2026/909 explains that this substance had been prohibited, but that, following the SCCS evaluation, it may be safely used as a preservative up to a maximum concentration of 1% in aerosol deodorants and powder foundations, provided that the silver content does not exceed 2.5%. As a consequence, it is removed from Annex II and added to Annex V as an authorised preservative under those conditions.
This type of amendment is especially relevant because regulatory changes do not always mean “more prohibition”. Sometimes they involve a regulatory repositioning of the substance, with specific conditions of use that must be perfectly aligned with the formulation and the product type.
UV filters and purity: the case of DHHB
In the case of DHHB, the critical point is not the prohibition of the UV filter itself, but the presence of DnHexP as a trace impurity. Regulation 2026/909 states that the SCCS considered a certain trace level to be safe, and that the Commission and the Member States ultimately agreed to set a maximum of 10 ppm of DnHexP as an unavoidable trace impurity in DHHB, also taking into account the economic impact on manufacturers, especially for sunscreen products. This change is also subject to the transitional timetable of 1 January 2027 for placing on the market and 1 July 2028 for making available on the market of non-compliant products.
This point is especially sensitive for sunscreens, because compliance here does not depend only on the INCI name of the filter, but also on the actual quality of the raw material and the documentary traceability of that purity.
Key dates of Regulation 2026/909
For practical purposes, the Regulation sets out three main milestones:
- 18 May 2026: entry into force of Regulation (EU) 2026/909.
- 1 January 2027: date from which non-compliant products affected by the new restrictions or prohibitions may no longer be placed on the EU market.
- 1 July 2028: general date from which those products may no longer be made available on the Union market. For certain entries related to Citral, the applicable date is extended to 1 August 2028.
In cosmetic regulation, confusing “placing on the market” with “making available on the market” remains a fairly popular corporate sport. Not a smart one, obviously.
What Regulation 2026/909 requires from brands and manufacturers
The publication of this Regulation requires, at a minimum, a review of several points:
- formulations and actual concentrations of the substances concerned;
- raw material specifications and impurities;
- product technical documentation, including the PIF and the CPSR;
- labelling compliance;
- reformulation planning or gradual withdrawal;
- and transitional dates applicable to each ingredient.
Not all the affected ingredients imply the same level of urgency, but all of them require a real technical review. And the earlier this is done, the less likely it is that compliance will end up being managed through panic, immobilised stock and uncomfortable emails.
How SHAPYPRO can help
In this context, SHAPYPRO can help manufacturers and brands review the regulatory impact of Regulation 2026/909 on their products, identifying whether a substance is prohibited, restricted or subject to new conditions regarding purity, concentration or labelling. This includes reviewing formulations, raw materials, technical documentation and transition strategy to ensure that the product remains compliant within the new regulatory deadlines.
Conclusion
Regulation 2026/909 is not a minor update. It introduces concrete changes to relevant cosmetic ingredients, modifies key annexes of Regulation 1223/2009 and obliges the industry to review formulations, impurities, permitted uses and adaptation timelines. Some substances become prohibited, others restricted, and others become subject to much more precise technical conditions.
For cosmetic companies, the correct reading of the Regulation should not remain a simple list of names. What matters is translating those changes into real decisions about product, documentation and market strategy. Because the Regulation has already been published. The optional part, unfortunately, was having started earlier.