New ATP Regulation 2026/909 has been published, which amends the Cosmetics Regulation.

Commission Regulation (EU) 2026/909 has been published, amending Cosmetics Regulation (EC) No. 1223/2009 by introducing new restrictions, bans, and conditions of use for numerous substances used in cosmetic products.

The measure affects Annexes II, III, V and VI of the Cosmetics Regulation and incorporates several opinions from the CSSC (Scientific Committee on Consumer Safety), with significant impacts in particular for:

• allergenic fragrances;

• ingredients containing aluminum;

• zinc salts;

• hair dyes;

• UV filters;

• preservatives.

Among the main new features we highlight:

• Triphenyl Phosphate (TPP) The substance “Triphenyl Phosphate” is included in Annex II (banned substances), following concerns regarding its potential genotoxic and endocrine profile.

Deadlines:

• from 1 January 2027: ban on placing non-compliant products on the market;

• from 1 July 2028: ban on making available on the market.

  
  

• Benzyl Salicylate The substance, already subject to the obligation to declare as a perfume allergen, is now subjected to specific limits differentiated by product category.

Some examples:

• perfumes: max 4%;

• shower gel/bath products: max 1.3%;

• body lotions: max 0.7%;

• oral products: max 0.004%.

The labelling requirements for fragrance allergens remain applicable.

• Citral Citral is also subjected to new product category-specific use limits, based on the QRA2 methodology for sensitization risk.

Among the main limitations:

• deodorants/antiperspirants: 0.032%;

• lip products: 0.11%;

• perfumes: 0.6%;

• leave-on hair products: 1.2%.

The obligation to declare perfume allergens on the label is confirmed.

• Ingredients containing aluminium A new entry dedicated to ingredients containing aluminium is introduced, with maximum limits expressed in terms of Al content for numerous cosmetic categories.

Examples:

• non-aerosol antiperspirants: 7.73%;

• aerosol deodorants: 3.24%;

• toothpastes: 3.18%;

• eyeshadows: 43.31%;

• leave-on facial products: 10.59%.

Particular attention should be paid to spray products and inhalable products.

• Water-soluble zinc salts The conditions of use of zinc salts in oral hygiene products are updated.

New limits:

• toothpastes: max 1% zinc;

• toothpastes for children 6 months – 1 year: max 0.72%;

• mouthwashes: max 0.1% for users over 6 years old.

  
  

• Acetylated Vetiver Oil Acetylated vetiver oil is included in Annex III with differentiated limits depending on the type of product.

It is also required that the raw material be stabilized with 1% alpha-tocopherol.

• New hair dyes New entries are introduced relating to:

• HC Blue No. 18;

• HC Yellow No. 16;

• HC Red No. 18;

• Hydroxypropyl-p-phenylenediamine and its dihydrochloride salt.

The substances are authorized within specific limits of use and with the usual mandatory warnings for hair colorants.

• DHHB (Diethylamino Hydroxybenzoyl Hexyl Benzoate) For the DHHB UV filter, a limit is introduced relating to the presence of the impurity DnHexP (di-n-hexyl phthalate), which must not exceed 10 ppm.

Application timeframes

For most substances:

• From 1 January 2027: ban on placing non-compliant products on the market;

• From 1 July 2028: no longer available on the market.

Different deadlines are foreseen for some specific substances.

Operational considerations

The regulation will require:

• review formulas and specific raw materials;

• check impurity levels;

• update PIF and CPSR dossiers;

• reevaluate labelling and claims;

• plan inventory management and regulatory transitions.

We recommend starting a gap analysis on the affected products as soon as possible, especially for the following categories:

• deodorants and antiperspirants;

• perfumery;

• oral care;

• hair dyes;

• products containing aluminum, clays or DHHB.

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We remain available to support formulation and documentation compliance checks.