Cosmetics · Proposed changes
CBD, BHA and butylparaben: what changes is the EU planning?
A draft amendment to the Cosmetics Regulation addresses bans and restrictions for several ingredients. Reviewing formulas and supplier information now makes sense, while planned measures should be clearly distinguished from requirements already in force.
Status checked on 10 November 2026.
Companies using CBD, BHA or butylparaben in cosmetic products should monitor the planned amendments to the annexes of the Cosmetics Regulation. Through notification G/TBT/N/EU/1219, the European Commission presented a draft covering several ingredients and different types of measures. An early portfolio review can help companies prepare before planning changes to production.
What does the published draft cover?
The European Commission’s official notification lists proposed bans on Benzophenone-1, Benzophenone-2, Basic Brown 16, Basic Blue 99 and prostaglandin analogues, among other measures. For BHA, butylparaben, CBD and hydroxyapatite in nanoform, it describes the introduction or revision of restrictions linked to the assessed conditions of safe use.
The draft also includes amendments resulting from new classifications of substances as carcinogenic, mutagenic or toxic for reproduction (CMR). Describing the whole package simply as a “ban on cosmetic ingredients” would therefore be misleading: some measures concern prohibitions, while others set conditions of use.
A draft and an applicable regulation are different stages
The notification was published in July 2026, with a deadline for comments of 6 September 2026. A newer text, D117774/02, was transmitted to the Council of the EU on 21 September 2026 as a draft. The end of the comment period does not, in itself, mean that the measures have been adopted or have become applicable. Before making a business decision, check EUR-Lex for any final act, its wording and transitional provisions.
An SCCS opinion and a CLP classification are also different documents. Article 15 of the Cosmetics Regulation addresses the use of CMR substances and the conditions for possible exceptions. Each substance therefore requires a review of the complete legal basis, beyond the news headline. The starting point is Regulation (EC) No 1223/2009.
What information should you gather for your products?
We recommend listing products containing the ingredients concerned and recording the precise substance identity, concentration, intended function and product type for each one. A raw material’s trade name is often insufficient for this review; INCI names, CAS numbers and supplier specifications are also useful.
Flag incomplete information separately. Rather than assuming an ingredient is absent, request clarification from the supplier. For blended raw materials, include the components of the mixture where relevant to the restriction being considered.
How can you plan a possible replacement?
If you identify potentially affected formulas, we recommend a preliminary assessment of feasible alternatives. Allow time for obtaining samples, developing the formula, carrying out necessary tests and reviewing safety documentation. Ask the supplier of a replacement raw material specific questions about identity, quality and the evidence available.
Link decisions on definitive formula changes and stock to the confirmed legal status. An internal plan can separate preparatory work from measures requiring the final wording and application date.
Review the impact on your formulas
BiSafe helps review ingredient restrictions and cosmetic product documentation. Send the composition and intended use to info@bisafe.si. Find out more about our cosmetic product services.
