EU Proposes Cosmetics Regulation Changes to Annexes II, III, V

The European Union has proposed revisions to Annexes II, III and V of its Cosmetics Regulation — the lists that govern which substances are banned, restricted or approved as preservatives in cosmetic products sold across the bloc, according to a report from regulatory consultancy CIRS Group. CIRS Group tracks chemical and cosmetics compliance rules for manufacturers that sell into the EU, and its report flags the three annexes as the focus of the pending changes, though it does not itemize every substance under review in the summary available.

What Is the EU Proposing to Change?

The proposal targets three of the regulation's annexes rather than a single ingredient list. Annex II, III and V amendments typically move through the European Commission with input from the EU's Scientific Committee on Consumer Safety before member states vote on adoption. CIRS Group's report identifies the annexes affected but does not publish a finalized substance-by-substance list in the material reviewed, so manufacturers awaiting specifics will need to watch the Commission's official channels for the draft text once it is published.

What Do Annexes II, III and V Cover?

Under the EU's cosmetics framework, each annex serves a distinct function. Annex II is the list of substances prohibited outright in cosmetic products marketed in the EU. Annex III covers substances that are not banned but are restricted — meaning they can appear only below a set concentration, in specific product types, or with required warning labels. Annex V is the positive list of preservatives that are permitted in finished cosmetics, each with its own maximum allowed concentration. A proposal touching all three annexes at once suggests the update spans multiple categories of ingredient risk rather than a single class of chemical.

Why Do These Annexes Get Updated?

The EU revises these annexes periodically as new safety data, toxicology studies or risk assessments come in, moving substances between categories — from restricted to banned, for instance, or adding new preservatives to the approved list. This is a routine mechanism built into the Cosmetics Regulation rather than a one-time event, which is why brands selling in the EU are expected to monitor annex changes on an ongoing basis rather than treating any single update as final.

How Would This Affect Beauty Brands and Consumers?

For manufacturers, an amendment to Annex II typically means reformulating any product containing a newly banned substance before a compliance deadline set in the final rule. Changes to Annex III can require adjusted concentrations or new labeling. Updates to Annex V can either expand or narrow the list of preservatives brands are allowed to use, which affects shelf-stability formulations across skincare and cosmetics lines. For consumers, the practical effect shows up later — in reformulated products, updated ingredient labels, or preservative substitutions in items already on store shelves. Readers following ingredient-level questions, such as how retinol and retinal are regulated differently in skincare formulations, can find related coverage in HTT's explainer on retinol versus retinal and general formulation guidance in science-backed skin care tips.

Regulatory scrutiny of beauty and fashion labeling in the EU is not limited to ingredient annexes. A separate report examined how Milan fashion week put the "Made in Italy" label under scrutiny, reflecting broader European regulatory attention on how consumer products are sourced, labeled and marketed.

Where Can the Proposal Be Tracked?

CIRS Group's report is the originating account of the proposed annex changes. Formal amendments to the EU Cosmetics Regulation are published through the European Commission's rulemaking process and voted on by member states before taking legal effect, with transition periods typically set for manufacturers to reformulate or relabel affected products. Brands and formulators with products sold in the EU are advised to confirm the final substance list once the Commission publishes the adopted text, since CIRS Group's summary names the annexes involved but stops short of a complete ingredient breakdown.

Regulation at a Glance

• Annexes named in the proposal: II (prohibited substances), III (restricted substances) and V (permitted preservatives)
• Regulation affected: the EU's Cosmetics Regulation, which governs product safety and labeling for cosmetics sold across the bloc

The scope of the final rule — including effective dates and any phase-in period for reformulation — was not detailed in the available report and would need to be confirmed once the Commission's draft text is published.

mindfulAI Keyboard — An iPhone keyboard that rewrites a draft in a tone you pick. Four free AI actions a day.