Hi everyone, Yeannie here! 🙋♀️🩷 I want to share something that came up in an R&D team meeting this week. PM had passed along a formulation review for one of our Europe-bound projects, and mid-meeting, R&D said, “we might need to look at this again — the EU just changed the rules on this one.” I was sitting in, and honestly, it felt like something too useful to keep just within our team. So today I’m writing it all up for you. If you’re shipping to Europe, please read this one through — the deadline is closer than it looks.
What Changed — EU 2026/909 (“Omnibus 2”) at a Glance
On April 27, 2026, the European Commission published Regulation (EU) 2026/909, amending the existing Cosmetics Regulation (EC No 1223/2009). The industry calls it “Omnibus 2,” and it took effect on May 18, 2026. This update touches twelve ingredients, and each one carries its own action level and deadline — here’s the breakdown.
| Ingredient | Action | Market-entry cutoff | Sell-through cutoff |
|---|---|---|---|
| Triphenyl Phosphate | Full ban | Jan 1, 2027 | Jul 1, 2028 |
| Citral | New max concentration by product type/area | Jan 1, 2027 | Jul 1, 2028 |
| Benzyl Salicylate | New usage limits | Jan 1, 2027 | Jul 1, 2028 |
| Aluminium compounds | Concentration limits by category | Jan 1, 2027 | Jul 1, 2028 |
| Water-soluble zinc salts (oral hygiene) | Revised usage conditions | Jan 1, 2027 | Jul 1, 2028 |
| 4 hair dye ingredients (HC Blue No.18, etc.) | Newly listed/restricted | May 18, 2026 — no grace period, already in effect | — |
| UV filter DHHB | New impurity limits | Jan 1, 2027 | Jul 1, 2028 |
Worth remembering: the four hair dye ingredients carry zero grace period, and the regulation already restricts them today. On top of that, everything else blocks new market entry starting January 1, 2027, and you can’t sell existing stock after July 1, 2028. It sounds far off, but once you factor in reformulation and stability retesting time, this is a “start now” timeline, not a “get to it later” one.
Yeannie’s buyer tip — With 12 ingredients changing at once, checking every raw material against the regulation one by one isn’t realistic for a brand team. That’s exactly why we build this into our formulation process as a standing check — you don’t need to cross-reference your ingredient list yourself. Just ask us whether your current formula touches any of these 12.
The Triphenyl Phosphate Ban — Why It Happened and By When
The heaviest measure in this update is the full ban on Triphenyl Phosphate. In a July 2024 opinion, the EU’s Scientific Committee on Consumer Safety (SCCS) concluded it couldn’t rule out genotoxicity for this ingredient, and this regulation acts on that conclusion. In other words, this isn’t a use-case restriction — it’s a complete ban across every cosmetic category, which is what makes this the headline change.
Yeannie’s buyer tip — Brands mostly use triphenyl phosphate as a plasticizer, so replacing it tends to affect texture and wear — things like spreadability and longevity. We’ve worked through this exact type of plasticizer substitution across a number of projects, aiming to keep sensory performance as close to the original as possible. You can see the categories and formulation work we’ve done on our SPSCOS formula page.
Citral, Benzyl Salicylate, and the Concentration-Limited Ingredients
Not every change here is an outright ban — several ingredients now carry new or lower concentration ceilings. Citral and Benzyl Salicylate, both common fragrance components, now have new maximum concentrations set by product type and application area. Aluminium compounds also picked up category-based concentration limits.
Not every change here is an outright ban — several ingredients now carry new or lower concentration ceilings instead. Citral and Benzyl Salicylate, both common fragrance components, now come with new maximum concentrations that vary by product type and application area. Aluminium compounds also picked up category-based concentration limits.
These are easy to miss precisely because they’re “restricted,” not “banned.” A perfumer usually formulates fragrance compounds separately, so manufacturers don’t always have full visibility into their exact composition. As we mentioned in our earlier post on Australia’s retinal restriction , ingredient regulation isn’t just about “I didn’t add it, so it’s not my problem” — it’s about whether you actually know the full composition of everything in your formula.
Yeannie’s buyer tip — Checking a fragrance supplier’s IFRA compliance is a standard step in our formula approval process, and we now check EU 2026/909 alignment in that same step too. The goal is simple: a brand should never have to go back to their fragrance supplier separately to ask “are we covered?” — we’ve already asked.
So This Is How SPSCOS Builds Around It
A regulation only tells you which ingredients to avoid or cap — it doesn’t tell you how to carry that into your actual formula. That’s the gap we close. We build ingredient regulation checks into the formulation process by default, and we propose substitutes without sacrificing sensory performance, on every project, as a matter of course. If you want to confirm whether a product you’re currently developing touches any of these 12 ingredients, reach out to our team — we’ll review your formulation sheet and walk through substitution options together. → Get in touch