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  • Writer's picturePharmilab

The differences in ingredients between EU and UK regulations

Updated: Nov 23, 2023

Since leaving the European Union, the United Kingdom has established its own regulation on cosmetic products. However, while the primary text (similar to EU Regulation 1223/2009) has been published, its appendices, which describe the conditions of use for the numerous ingredients, have not yet been published. As a result, there are variations in the legislation for almost ten substances, which CTPA (Cosmetic, Toiletry and Perfumery Association) listed.

The Cosmetic, Toiletry and Fragrance Association (CTPA) in the UK published a public statement on the legal status of Butylphenyl Methylpropional on February 14, 2022. The aim was to clarify the rules applicable to this ingredient, which will be banned in Europe from March 1, 2022, but which is only subject to labeling as an allergen in the UK.

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

How are cosmetics regulated in the United Kingdom?

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

For this reason, products marketed throughout the United Kingdom (Great Britain and Northern Ireland) must comply with both rules. This will undoubtedly lead to increased uncertainty, since if the fundamental texts follow the same logic, their appendices would not.

Divergent annexes

The annexes to the Cosmetics Regulation cover the conditions of use for a variety of categories of ingredients:

  • Annex II: prohibited substances

  • Annex III: ingredients subject to restrictions

  • Annex IV: dyes

  • Annex V: preservatives

  • Annex VI: UV filters

The UK has not yet published these appendices. The provisions of the EU Regulation have been implemented, as of December 31, 2020

The point is that while most of the EU regulatory adjustments made since January 1, 2021, should eventually be implemented in the UK, they haven't been made yet.

"Many of the changes to the EU Cosmetics Regulation, which came into force on January 1, 2021, are set 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 yet know when this will happen." According to the CTPA

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

The 9 differences

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