UK Cosmetic Ingredient Restrictions: Complete Guide
The UK regulates cosmetic ingredients through a system of Annexes to UK Retained Regulation 1223/2009, as amended by Statutory Instruments. According to UK legislation, these annexes define which substances are prohibited, restricted, or permitted under specific conditions.
UK-EU Regulatory Divergence
Understanding the UK Annex System
| Annex | Purpose | Example Substances |
|---|---|---|
| Annex II | Prohibited substances — cannot be used | Hydroquinone (most uses), mercury compounds, chloroform |
| Annex III | Restricted substances — permitted with conditions | Hydrogen peroxide (max %), salicylic acid (max %), certain UV filters |
| Annex IV | Permitted colorants — positive list | CI 77891 (titanium dioxide), CI 77491 (iron oxides) |
| Annex V | Permitted preservatives — positive list | Phenoxyethanol (max 1%), parabens (with limits) |
| Annex VI | Permitted UV filters — positive list | Octinoxate (max 10%), avobenzone (max 5%) |
Source: UK Retained Regulation 1223/2009
How the Annex System Works
UK Ingredient Compliance Logic
- Check Annex II first — if substance is listed, it is PROHIBITED (no exceptions)
- Check Annex III — if listed, use only within stated concentration/conditions
- Colorants MUST be in Annex IV — unlisted colorants are prohibited
- Preservatives MUST be in Annex V — unlisted preservatives cannot be used as preservatives
- UV filters MUST be in Annex VI — unlisted UV filters cannot make SPF claims
- CMR substances (Category 1A, 1B, 2) are prohibited unless specifically exempted
- Nanomaterials require separate notification and may have specific restrictions
Key Prohibited Substances (Annex II)
According to UK Annex II, over 1,600 substances are completely banned in cosmetics. Here are notable examples:
| Substance | Common Name/Use | Why Prohibited |
|---|---|---|
| Hydroquinone | Skin lightening | Except for professional nail products |
| Mercury and compounds | Historical preservative | Toxicity |
| Lead compounds | Historical colorant | Toxicity |
| Formaldehyde (>0.1%) | Preservative | Carcinogen above threshold |
| Chloroform | Solvent | Carcinogen |
| Boric acid | Preservative (most uses) | Reproductive toxicity |
| Butylphenyl methylpropional (Lilial) | Fragrance | Reproductive toxicity (banned March 2022) |
| Retinyl palmitate (>0.3% face, >0.05% body) | Anti-aging | EU 2025 restriction — UK adoption pending |
| Homosalate (>7.34%) | UV filter | Reduced limit from 10% (2025) |
* This is a sample — full Annex II contains 1,600+ entries
Source: UK Retained Regulation 1223/2009, Annex II
CMR Substances
CMR (Carcinogenic, Mutagenic, Reprotoxic) substances classified as Category 1A, 1B, or 2 are automatically prohibited unless:
- Used below a 'safe' threshold defined by SCCS/UK expert committee
- Specifically exempted in Annex III with conditions
- The classification is disputed with scientific evidence
CMR Updates
Key Restricted Substances (Annex III)
| Substance | Restriction | Product Type | Required Warnings |
|---|---|---|---|
| Salicylic acid | Max 2% | Leave-on (not for under 3s) | 'Not for children under 3' |
| Hydrogen peroxide | Max 12% (hair) | Hair products | Percentage + 'Keep away from eyes' |
| Aluminium compounds | Max 6.25% non-spray / 10.6% spray (as Al) | Antiperspirants/deodorants | SCCS recommendation |
| Retinol/Retinyl esters | Max 0.3% RE face / 0.05% RE body (EU 2025) | Anti-aging products | Vitamin A warning — UK adoption pending |
| Thioglycollic acid | Max 11% (hair) | Depilatory/perm | 'Keep away from children' |
| Ammonia | Max 6% (as NH₃) | Hair products | 'Avoid contact with eyes' |
| Resorcinol | Max 1.25% oxidative dye / 0.5% lotions | Hair dyes, lotions, shampoos | 'Not for eyelashes/eyebrows' (at 1.25%) |
Source: UK Retained Regulation 1223/2009, Annex III
2024-2025 UK Restriction Updates
According to CTPA regulatory updates, recent UK Statutory Instruments have implemented:
| Substance | Old Limit | New Limit | Effective Date |
|---|---|---|---|
| Retinyl palmitate (face/hand) | No limit | 0.3% RE (0.05% body) | EU Nov 2025 — UK pending |
| Retinol (face/hand) | No limit | 0.3% RE (0.05% body) | EU Nov 2025 — UK pending |
| Homosalate | 10% | 7.34% | July 2025 |
| Benzophenone-3 (Oxybenzone) | 6% | 6% (under review) | Current |
| Methyl salicylate | Varies | Stricter limits (children's) | March 2025 |
* UK implementation dates may differ from EU. Verify current status.
Source: CTPA regulatory updates
Vitamin A Restrictions — EU Limits (UK Pending)
Fragrance Allergens
The UK currently requires declaration of 26 fragrance allergens when present above threshold concentrations:
| Product Type | Declaration Threshold | Example |
|---|---|---|
| Leave-on products | 0.001% (10 ppm) | Moisturizers, serums, makeup |
| Rinse-off products | 0.01% (100 ppm) | Shampoo, body wash, soap |
Source: UK Retained Regulation 1223/2009, Annex III
The 26 Declarable Allergens
| INCI Name | Common Name | Notes |
|---|---|---|
| Alpha-isomethyl ionone | Floral/violet | Common in perfumes |
| Amyl cinnamal | Jasmine-like | In fragrances |
| Amylcinnamyl alcohol | Floral | In fragrances |
| Anise alcohol | Anise-like | In fragrances |
| Benzyl alcohol | Mild | Also used as preservative |
| Benzyl benzoate | Balsamic | In perfumes |
| Benzyl cinnamate | Balsamic | In perfumes |
| Benzyl salicylate | Floral | Common fixative |
| Cinnamal | Cinnamon | In spicy fragrances |
| Cinnamyl alcohol | Cinnamon | In spicy fragrances |
| Citral | Lemon/citrus | In citrus oils |
| Citronellol | Rose/citrus | In rose oils |
| Coumarin | Vanilla/hay | In oriental perfumes |
| Eugenol | Clove | In spice oils |
| Farnesol | Floral | In essential oils |
| Geraniol | Rose | In geranium oil |
| Hexyl cinnamal | Jasmine | Common in perfumes |
| Hydroxycitronellal | Floral | Lily of valley |
| Hydroxyisohexyl 3-cyclohexene carboxaldehyde (HICC) | Lily/floral | Being phased out EU, check UK status |
| Isoeugenol | Clove | In spice oils |
| Limonene | Citrus/orange | In citrus oils |
| Linalool | Floral/lavender | Very common |
| Methyl 2-octynoate | Violet | In violet fragrances |
| Evernia furfuracea extract | Treemoss | Oak moss absolute |
| Evernia prunastri extract | Oakmoss | Oak moss absolute |
| Butylphenyl methylpropional (Lilial) | Lily | BANNED (March 2022) |
* Note: Lilial is now prohibited entirely, not just requiring declaration
Source: UK Retained Regulation 1223/2009, Annex III
UK vs EU Fragrance Allergen Divergence
Colorants, Preservatives, and UV Filters
Annex IV: Permitted Colorants
Only colorants listed in Annex IV may be used in cosmetics. Key categories:
| Category | Examples | Restrictions |
|---|---|---|
| All cosmetics | CI 77891 (titanium dioxide), CI 77491-77499 (iron oxides) | May be used in all cosmetics |
| Except eye area | CI 77266 (carbon black) | Cannot be used in eye products |
| Rinse-off only | Some synthetic dyes | Cannot be in leave-on products |
| Hair dyes only | Oxidative dye precursors | Cannot be in other products |
Source: UK Retained Regulation 1223/2009, Annex IV
Annex V: Permitted Preservatives
Only listed preservatives may be used for antimicrobial preservation:
| Preservative | INCI Name | Maximum Concentration |
|---|---|---|
| Phenoxyethanol | Phenoxyethanol | 1.0% |
| Methylparaben | Methylparaben | 0.4% (0.8% as mixtures) |
| Ethylparaben | Ethylparaben | 0.4% (0.8% as mixtures) |
| Propylparaben | Propylparaben | 0.14% |
| Butylparaben | Butylparaben | 0.14% |
| Benzyl alcohol | Benzyl Alcohol | 1.0% |
| Sorbic acid | Sorbic Acid | 0.6% |
| Benzoic acid | Benzoic Acid | 2.5% (leave-on), 5% (rinse-off) |
* Propylparaben and Butylparaben banned in leave-on products for nappy area (under 3 years)
Source: UK Retained Regulation 1223/2009, Annex V
Annex VI: Permitted UV Filters
Only listed UV filters may be used with SPF claims:
| UV Filter | INCI Name | Maximum Concentration |
|---|---|---|
| Octinoxate | Ethylhexyl Methoxycinnamate | 10% |
| Avobenzone | Butyl Methoxydibenzoylmethane | 5% |
| Octocrylene | Octocrylene | 10% |
| Homosalate | Homosalate | 7.34% (reduced 2025) |
| Titanium dioxide | Titanium Dioxide | 25% |
| Zinc oxide | Zinc Oxide | 25% |
| Tinosorb S | Bis-Ethylhexyloxyphenol Methoxyphenyl Triazine | 10% |
| Tinosorb M | Methylene Bis-Benzotriazolyl Tetramethylbutylphenol | 10% |
Source: UK Retained Regulation 1223/2009, Annex VI
Nanomaterials
Nanomaterials (1-100nm) in cosmetics have specific requirements:
UK Nanomaterial Requirements
- Must be notified to SCPN with specific nanomaterial data
- Safety assessment must address nano-specific risks
- Must be labeled with '(nano)' after ingredient name
- Some nanomaterials are restricted (e.g., certain carbon forms)
- Titanium dioxide and zinc oxide nano forms have specific usage conditions
Nano Titanium Dioxide
How to Verify UK Ingredient Compliance
Ingredient Compliance Verification Process
Identify All Ingredients
List all ingredients by INCI name, including fragrance components and impurities above declarable levels.
Check Annex II (Prohibited)
Search UK Annex II for each ingredient. If found, the substance is BANNED and cannot be used.
Check Annex III (Restricted)
If in Annex III, note concentration limits, product type restrictions, and required warnings.
Verify Colorants Against Annex IV
All colorants must be in Annex IV. Check any restrictions on usage (eye area, rinse-off, etc.).
Verify Preservatives Against Annex V
If using a substance for antimicrobial preservation, it must be in Annex V within concentration limits.
Verify UV Filters Against Annex VI
If making SPF claims, all UV filters must be in Annex VI within concentration limits.
Check CMR Status
Verify no ingredients have been recently classified as CMR 1A, 1B, or 2 under CLP Regulation.
Document in CPSR
The safety assessor should verify all ingredients and document compliance in the CPSR.
Where to Find Current UK Annexes
| Resource | URL | Notes |
|---|---|---|
| UK Legislation Portal | legislation.gov.uk | Search for 'Cosmetic Products Enforcement Regulations' |
| OPSS Guidance | gov.uk/guidance/cosmetic-products-guidance | Plain English interpretation |
| CTPA Technical Resources | ctpa.org.uk | Membership required for full access |
| EUR-Lex (EU baseline) | eur-lex.europa.eu | Reference only — may differ from UK |
Source: UK Government
Check UK Annex II (prohibited substances) at legislation.gov.uk. Search for the INCI name or CAS number. If listed, the substance is banned. Also check if it's a CMR substance (Category 1A, 1B, or 2) which is automatically prohibited unless specifically exempted.
Not anymore. While they share the same baseline (Regulation 1223/2009), the UK and EU have begun diverging since Brexit. Examples include: fragrance allergens (26 UK vs 80+ EU), timing of vitamin A restrictions, and some UV filter limits. Always verify against current UK annexes.
The UK requires declaration of 26 fragrance allergens when present above 0.001% in leave-on products or 0.01% in rinse-off products. This is fewer than the EU's new 80+ allergen list. Note: Lilial (Butylphenyl methylpropional) is now completely banned, not just requiring declaration.
Yes, certain parabens remain permitted in UK cosmetics: methylparaben and ethylparaben up to 0.4% (0.8% as mixtures), propylparaben and butylparaben up to 0.14%. However, propyl/butylparaben are banned in leave-on products for the nappy area of children under 3 years.
The EU has set limits under Regulation (EU) 2024/996: 0.3% Retinol Equivalent (RE) for face/hand products and other leave-on/rinse-off products, 0.05% RE for body lotions. Products must carry warnings advising pregnant and breastfeeding women not to use them. Note: The UK has NOT yet adopted these EU limits — UK brands should monitor regulatory updates.
Nanomaterials (1-100nm) must be: (1) notified to SCPN with specific nano data, (2) safety assessed for nano-specific risks, and (3) labeled with '(nano)' after the ingredient name. Some nanomaterials have specific restrictions — e.g., nano titanium dioxide cannot be used in spray products.
The official source is legislation.gov.uk — search for 'Cosmetic Products Enforcement Regulations' and subsequent amending Statutory Instruments. OPSS publishes guidance at gov.uk, and CTPA provides technical resources for members. Note: EUR-Lex shows EU annexes which may differ from UK.
Using a prohibited (Annex II) ingredient means your product cannot legally be sold in the UK. Enforcement can include product seizure, unlimited fines, and potential prosecution. Your CPSR would also be invalid if it approved a prohibited ingredient, and your UK RP could face liability.
Check Your Ingredient Compliance
Verify your cosmetic ingredients against current UK restrictions.
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