The ingredients differences between Europe and the UK regulations.

  • February 14, 2023

Since the UK's withdrawal from the European Union, it has established its own cosmetic products regulation. However , if the primary text (similar to EU Regulation 1223/2009) has been published, its appendices, which describe the numerous ingredients' usage conditions, have not yet been published. As a result of this, there are variations in legislation for almost ten substances, which the CTPA (Cosmetics, Toiletry and Perfumery Association) has listed.


The Cosmetic, Toiletry and Fragrance Association (CTPA) in the United Kingdom published a public declaration on the legal status of Butylphenyl Methylpropional on February 14, 2022. The objective was to clarify the rules that will apply to this ingredient, which will be banned in Europe beginning March 1, 2022, but which is only subject to labelling as an allergen in the UK.

This was a great chance for the CTPA to point out the framework of today's cosmetics rules on both sides of the Channel, as well as their differences.


In the United Kingdom, how are cosmetics regulated?

 Since the United Kingdom's withdrawal from the European Union, all cosmetics put on sale in Great Britain (England, Wales, and Scotland) must comply with Annex 34 of the Product Safety and Metrology Statutory Instrument. The European Cosmetics Regulation 1223/2009 is still in force for Northern Ireland.

Because of this, goods marketed throughout the UK (Great Britain and Northern Ireland) must fulfill both rules. This will undoubtedly lead to a rise in uncertainty, since if the fundamental texts follow the same logic, their appendices would not.

Diverging annexes: 

The Cosmetics Regulation's annexes cover the conditions of usage for a variety of ingredient categories:

  • Annexe II: prohibited substances
  • Annexe III: ingredients subject to restrictions
  • Annexe IV: colorants
  • Annexe V: preservatives
  • Annexe VI: UV filters

The United Kingdom has not yet published these appendices. The EU Regulation's provisions have been implemented, as of December 31, 2020.

The issue is that, while most of the EU's regulatory adjustments made since January 1, 2021, should be implemented in the UK eventually, they have not yet been done.

“Many of the EU Cosmetics Regulation's modifications, which took effect on January 1, 2021, are anticipated to be implemented in the UK once a clear procedure for managing cosmetic ingredients under the UK Cosmetics Regulation is in place. However, we don't know when this will happen yet.” According to the CTPA

As a result, the Association has so far identified nine cosmetic components that are subject to varied regulations on both sides of the Channel, and this list may be expanded as EU Regulation amended annexes.


The 9 differences


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