Cosmetic Ingredients Compliance in the UK, EU and USA (what changes in 2026)
Cosmetic ingredients compliance is no longer only about “what is inside the formula”. For brands placing products on the market in the UK, EU and USA, ingredients compliance means ensuring that:
- the formula is legally permitted in the target market
- cosmetic ingredient restrictions and bans are monitored continuously
- safety documentation is valid and up to date
- labelling reflects current regulatory requirements
- claims and marketing do not create compliance risks
This guide covers cosmetic ingredient restrictions, banned ingredients, concentration limits, INCI compliance, fragrance allergen obligations and compliance documentation in the UK, EU and USA. It also highlights the most important regulatory changes expected in 2026 and how brands can reduce compliance risk before launch.
In 2026, ingredient transparency and restriction enforcement will increase significantly, particularly in the UK and EU. In the USA, the regulatory landscape is also evolving rapidly due to MoCRA (Modernization of Cosmetics Regulation Act) and state-level reporting obligations.
This article explains what changes in 2026 and how to manage cosmetic ingredients compliance across the UK, EU and USA.
How to check cosmetic ingredients compliance in the UK, EU and USA
To verify cosmetic ingredients compliance, you must confirm that each ingredient is permitted in the target market, meets concentration limits and conditions of use, and does not trigger mandatory labelling or reporting obligations. In practice, compliance checks cover restricted and banned ingredients, INCI naming, fragrance allergen declarations and documentation currency.
What cosmetic ingredients compliance means in practice
From a regulatory perspective, ingredients compliance requires a brand to demonstrate that the product:
- uses permitted substances only
- meets concentration limits and conditions of use
- complies with restricted or banned ingredient lists
- has correct INCI naming and allergen declarations
- is supported by valid safety documentation
Compliance is not a one-time task. Ingredient regulations evolve continuously, and relying on outdated documentation creates avoidable legal and commercial risk.
Compliance is not procedural. It is an operational responsibility.
Key regulatory differences: UK vs EU vs USA
Below is a simplified comparison of the compliance focus across markets.
| Market | Regulatory focus | What brands must manage |
|---|---|---|
| UK | UK cosmetics legislation + notification | UK Responsible Person, notification, label compliance, ongoing monitoring |
| EU | Regulation (EC) No 1223/2009 + SCCS opinions | Annex restrictions, safety assessment, PIF maintenance, strict updates |
| USA | MoCRA + FDA framework + state rules | evolving safety governance, reporting obligations, supply chain transparency |
UK
Cosmetic products placed on the UK market must comply with UK cosmetics legislation and notification requirements. Ingredient restrictions largely mirror the EU framework, but compliance obligations remain market-specific and enforcement is handled independently.
This is where US brands usually fail: Responsible Person appointment and correct notification. Each product must have a designated Responsible Person established in the UK, who holds legal accountability for compliance.
Learn more about Responsible Person services here: Responsible Person services.
EU
EU compliance is based on Cosmetics Regulation (EC) No 1223/2009, including Annex restrictions, SCCS opinions and ongoing regulatory updates.
This is where the highest enforcement risk sits: Annex changes, banned ingredients updates and fragrance allergens labelling 2026 requirements. Scientific risk assessment is supported by SCCS opinions and guidance.
USA
Historically, US cosmetics regulation was less restrictive than the EU. However, the introduction of MoCRA (FDA overview) is changing expectations for compliance, reporting and safety governance.
MoCRA adds governance + documentation exposure: brands face greater accountability for safety substantiation, reporting obligations and supply chain transparency requirements. Additionally, state-level laws, such as California disclosure requirements, increase transparency obligations for certain ingredients and fragrance components.
For practical planning tools, you can also use our internal resource hub: Free Regulatory Guides.
2026 compliance changes affecting cosmetic ingredient lists
1) Fragrance allergens: major labelling expansion in the EU
In 2026, EU labelling requirements for fragrance allergens will expand significantly. The number of mandatory declared fragrance allergens will increase from the current list of 26 to more than 80 substances, following Regulation (EU) 2023/1545.
Many of these allergens are naturally present in essential oils, which means “natural” products may face the greatest labelling impact. Even when a formula does not contain synthetic fragrance ingredients, allergen thresholds can still trigger declaration obligations. This change increases label complexity and may require packaging redesign and reformulation decisions.
If you need a detailed implementation guide (thresholds, transition timelines and labelling strategy), see our full article on Regulation (EU) 2023/1545 fragrance allergen labelling.
2) “Parfum” is no longer a safe shield in the USA
In the USA, transparency expectations around fragrance composition are increasing. California’s reporting obligations already require disclosure of hazardous substances that were previously hidden under “Fragrance” or “Parfum” as trade secrets: California cosmetics reporting (CDPH).
This is a compliance and liability shift, not merely a marketing shift. Brands must ensure supply chain transparency and obtain full composition information from fragrance suppliers.
3) Transparency drives reformulation and risk reduction
When hazardous ingredients become reportable or restricted, brands often reformulate quickly to reduce legal and reputational risk. This trend is critical for compliance strategy. It is no longer sufficient to “pass” current requirements. Brands must adopt a proactive approach that anticipates future restrictions and evolving enforcement expectations.
4) CPSR alone is not a compliance strategy
In the UK and EU, a Cosmetic Product Safety Report (CPSR) is a legal requirement for placing products on the market. If you need a practical overview, see our guidance: CPSR guidance for US brands (Annel).
However, compliance does not stop at CPSR. Ingredient restrictions, allergen obligations, naming conventions and documentation requirements evolve continuously. A CPSR created months or years ago may no longer reflect current compliance requirements if ingredient rules have changed. A product can become non-compliant without any change to its formulation.
CPSR forms part of the wider Product Information File (PIF), which must be maintained and updated throughout the product lifecycle: Product Information File (PIF) EU and UK.
5) May 2026: hard deadline for restricted substances in the EU
Some regulatory changes include transition periods, while others introduce hard cut-off dates. The EU has confirmed compliance deadlines affecting substances classified as CMR (carcinogenic, mutagenic or toxic for reproduction). These deadlines create direct commercial risk. Products may require reformulation or withdrawal if they contain newly restricted substances.
This typically affects CMR reclassifications and Annex updates. Brands should identify high-risk ingredients early and plan mitigation actions before deadlines become operational emergencies.
6) UK, EU and USA standards are moving closer
The regulatory gap between the EU and the USA is narrowing. The USA is adopting more structured compliance expectations, while the EU continues to expand transparency and restriction requirements. For global brands, the direction is clear: compliance must be managed across markets using the highest standard approach, rather than reacting to each jurisdiction separately.
Ingredient compliance checklist for brands (UK, EU and USA)
If you manage product development, regulatory affairs or compliance operations, use this checklist to reduce risk:
- review restricted and banned ingredients for the target market
- confirm fragrance allergen thresholds and labelling impact
- validate INCI compliance, naming and mandatory declarations
- verify supplier documentation and full fragrance composition data
- ensure CPSR and product documentation are current
- monitor upcoming regulatory deadlines, including 2026 changes
- update labels and claims before launching or relaunching products
Common cosmetic ingredient compliance mistakes (UK, EU and USA)
Even experienced brands face compliance failures when cosmetic ingredient restrictions and documentation requirements change. The most common mistakes include:
1) Using outdated ingredient restriction lists
A product can become non-compliant without any formula change if ingredient classifications, concentration limits or Annex restrictions are updated. This is a frequent cause of enforcement actions during audits and market surveillance.
2) Assuming “natural” equals “low compliance risk”
Essential oils and botanical extracts often contain naturally occurring fragrance allergens that trigger mandatory declaration thresholds. This is a common issue under fragrance allergens labelling 2026 and INCI compliance reviews.
3) Not verifying full fragrance composition
Relying on “Parfum” or supplier summaries creates compliance gaps. Full fragrance composition data is essential, particularly where US state-level disclosure obligations and supply chain transparency requirements apply.
4) Treating CPSR as the only compliance deliverable
A CPSR supports safety assessment, but it does not replace ongoing ingredient monitoring, label updates and Product Information File (PIF) maintenance. Compliance failures often occur when CPSR documentation is not reviewed after regulatory changes.
5) Launching with claims that increase regulatory exposure
Claims can create compliance risk if they imply medical, therapeutic or physiological effects, mislead consumers or contradict safety documentation. Claims-driven enforcement is a common trigger for product suspension and corrective action.
Free compliance resources
If you want practical tools for compliance planning, you can download free PDF guides covering cosmetics compliance in the UK, EU and USA: Free Regulatory Guides.
You can also explore ongoing regulatory updates in the Annel Cosmetic Regulatory Blog: Annel Cosmetic Regulatory Blog.
FAQ
Do ingredient restrictions differ between the UK and EU?
In many cases they are aligned, but compliance obligations remain market-specific. Always verify requirements for the target market.
Will fragrance allergen changes impact “natural” cosmetics?
Yes. Many mandatory allergens are naturally present in essential oils, meaning natural products may require expanded labelling.
Do US regulations now require full ingredient transparency?
MoCRA and state-level reporting laws are increasing compliance obligations, particularly around safety governance and hazardous ingredient disclosure.
Do I need a separate CPSR for the UK and EU?
Often yes, depending on Responsible Person structure, documentation expectations and market-specific compliance approach. Brands should confirm requirements before placing products on each market.
What happens if an ingredient becomes restricted after launch?
The product may require reformulation, label updates or withdrawal depending on the restriction type and compliance deadlines. Continuous monitoring is essential to avoid enforcement risk.
How do I check if cosmetic ingredients are compliant before launch?
Check restricted and banned ingredients for the target market, verify concentration limits and conditions of use, confirm INCI naming and mandatory declarations, and assess fragrance allergen labelling and documentation validity. Use the checklist above to structure the review.
Where can I find restricted and banned cosmetic ingredient lists for the EU and UK?
EU and UK restrictions are primarily managed under Regulation (EC) No 1223/2009 Annexes and subsequent amendments. Always review the most current Annex updates and ensure your safety documentation reflects the latest restrictions.
Need support with cosmetic ingredients compliance?
Ingredient compliance failures often surface during inspections, product launches or enforcement actions. If you need help reviewing cosmetic ingredient restrictions, banned ingredients risk, INCI compliance, labelling requirements or compliance documentation for the UK, EU and USA, contact Annel’s regulatory team: contact Annel.