👋 - Kishan Babuji
Me, along with leaders from Shiseido, CANOPY and Jing Daily
Florian and I just wrapped our Asia tour after stops at inCos Bangkok and Cosmoprof Hong Kong. I joined a panel in Hong Kong to talk about AI, which has become everyone’s favorite buzzword, and how companies can get their data and processes in shape to actually benefit from it. After a hectic, exhilarating few weeks, we’re glad to be back stateside and focused on closing out the year strong.
One more update before we dive in. Karen will be speaking on an upcoming podcast, The Art of Scaling: Navigating Claims, Regulations & Packaging Strategies for Your Beauty Brand. If you want to join live on December 2, you can register here.
Regulatory Bytes From Karen
2025 EU Regulatory Changes: The Year in Review
Regulation/Act | Description | Effective Date |
|---|---|---|
Regulation (EU) 2025/877 (Omnibus Act VII) | Banned 22 substances newly classified as Carcinogenic, Mutagenic, or Toxic to Reproduction (CMRs) in cosmetics, amending Annex II of EC No 1223/2009. Requires removal of cosmetics containing these substances from the market. | September 1, 2025 |
Retinol and derivatives restrictions | Limits on maximum concentrations of Retinol, Retinyl Acetate, Retinyl Palmitate (0.05% in body lotions, 0.3% others) and mandatory labeling warning "Contains Vitamin A. Consider your daily intake before use." | November 1, 2025 |
Triclocarban and Triclosan bans | Prohibition of triclocarban and triclosan in cosmetic products; enforcement implies removal of non-compliant products. | October 31, 2025 |
Nanomaterial prohibitions | Bans several nanomaterials such as colloidal gold, silver, copper, platinum compounds in cosmetics, with labeling requirements for allowed nanomaterials. | November 1, 2025 |
PFAs bans | Prohibition of the manufacture, import, export, and sale of cosmetics containing PFAS in France. (Loi n° 2025-188 du 27 février 2025) | January 1, 2026 |
Draft amendments to Cosmetics Regulation | Proposed glossary update for ingredient names; updates to Annex III (restricted substances), IV (permitted colorants), V (preservatives) with adoption expected in early 2026; effective January 2027 for product placement. | Partial implementation planned 2026-2027 |
Omnibus Act VIII | Further restrictions on substances in cosmetic products with an anticipated enforcement date of May 1, 2026. Ingredients that will be restricted include Hexyl Salicylate, O-Phenylphenol and Silver Powder. Ingredients that will be banned are Silver in massive forms (particle diameter ≥ 1 mm) and silver nano (particle diameter > 1 nm ≤ 100 nm), Ter-butyl-2-ethylperoxyhexanoate and N,N'-methylenediacrylamide | Scheduled May 1, 2026 |
Formaldehyde-Donor Preservatives | The EU continues to allow some formaldehyde releasers like Quaternium-15 up to 0.2% concentration in cosmetics but is moving to further restrict or ban additional releasers through new Omnibus acts to improve safety. The UK has drafted regulations to ban several formaldehyde releasers alongside 16 other CMR substances as of October 2025. | Regulations expected in 2026 |
UK Cosmetic Restrictions | Restrictions on Methyl Salicylate in certain cosmetic formulations, adopted April 30, 2025, effective September 30, 2025 in UK. | September 30, 2025 |
Looking Ahead to 2026
Aminomethylpropanol, used as a buffering agent in cosmetics, is currently under evaluation for classification as a reprotoxic substance category 1B by the European Chemicals Agency (ECHA), based on a proposal from Austria submitted in December 2024. This proposed classification includes:
Skin corrosion category 1 (causing severe skin burns and eye damage)
Eye damage category 1
Reprotoxic 1B (may damage the unborn child)
Specific target organ toxicity from repeated exposure (liver damage)
Should this reprotoxic classification be adopted, aminomethylpropanol will be added to the EU Cosmetics Regulation Annex II as a banned CMR substance with an 18-month transition period after publication.
Currently, aminomethylpropanol is restricted under Annex III of the regulation due to possible nitrosamine formation (impurities leading to carcinogenic nitrosamines). While it is not yet banned, it is likely to be banned as a CMR substance in the near future pending regulatory decisions.
Four cosmetic ingredients currently under review in the EU draft amendment notified to the WTO for continued cosmetic use despite their CMR classification are:
Isohexadecane - a cleansing and emulsifying agent
Hydrogenated Styrene/Isoprene Copolymer - film former and plasticizer
Oligomeric Decyl Methacrylate - emollient and viscosity controlling agent
Decamethylcyclopentasiloxane (D5) - a volatile silicone used as an emollient and solvent
These substances have recently been reclassified as CMR (carcinogenic, mutagenic, or toxic for reproduction) under the EU CLP Regulation but are proposed to remain permitted in cosmetics under strict safety assessments by the Scientific Committee on Consumer Safety (SCCS). The draft proposal was submitted to the WTO on May 21, 2025, for public comment until July 20, 2025, and is expected to enter into force by May 1, 2026.
Some IRI-Sys News
Announcing: Custom Fields 🎉🎉
This week we’re introducing custom fields, a new way to tailor the IRI-Sys platform to your own workflows. You can add your own fields to ingredients, raw materials, fragrances, formulas, and Regi formulas, giving you full control over the data you track. Whether it’s internal IDs, supplier notes, sustainability metrics, or any other detail your team relies on, you can now capture it directly in the system. We’re excited to roll this out and see the creative ways teams put it to use!
Industry Buzz
Recent Mergers & Acquisitions
XINÚ & Estée Lauder
Estée Lauder has taken a minority stake in XINÚ, marking its first investment in a Latin American brand. Founded in 2017, the Mexican fragrance label is known for its design-driven, culturally rooted approach to scent. The deal, made through Estée Lauder’s New Incubation Ventures arm, highlights growing interest in independent fragrance houses emerging from the region. Learn more.