The Ever-Changing Landscape of Cosmetic Ingredient Safety

The topic of prohibited and restricted ingredients cannot be discussed without mentioning the systems and procedures which lead to the prohibition or restriction of such substances. The Scientific Committee of Consumer Safety (SCCS) is responsible for assessing the hazards and risks chemical substances pose to human health ​(European Commission, nn.d.)​ however, the implementations of any new restriction or prohibition are at the discretion of the European Commission (EC). This regulatory body decides whether to add a substance to the list of Annexes in the European Union Cosmetic Products Regulation (EU CPR) (Regulation (EC) No 1223/2009). The Scientific Advisory Group on Chemical Safety in Consumer Products abbreviated to SAG-CS is the United Kingdom‘s (UK‘s) equivalent to the SCCS and was established in its current form in 2021. The scientific body advises the Office for Product Safety and Standards (OPSS) on risks to human health, similar to the function of the SCCS ​(Scientific Advisory Group on Chemical Safety in Consumer Products – GOV.UK, n.d.)​. Which can then lead to updates in The Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019, SCHEDULE 34. 

The SCCS produces opinions which may influence the regulatory status of substances in the EU and prompt SAG-CS to perform their own investigations or adopt the findings. The most recent SCCS opinion was issued on the 18th of December 2025 on Silver ​(SCCS – Scientific Advice on Silver Used in Cosmetic Products (CAS/EC No. 7440-22-4/231-131-3) – Public Health, 2025)​. The study found that the substance with a particle size between 100 nm and 1 mm (CAS: 7440-22-4) is safe for use at a maximum concentration of 0.2% in rinse-off and 0.3% in leave-on cosmetic products. The European Commission has published Commission Regulation (EU) 2026/78 of 12 January 2026 amending Regulation (EC) No 1223/2009 which amends Annex II (prohibited substances) and Annex III (restricted substances) to reflect the findings of the SCCS study. ​(Regulation – EU – 2026/78 – EN – EUR-Lex, n.d.)​. This change was included in the revision of the EU CPR due to the classification of silver under the Classification, Labelling, and Packaging (CLP) Regulation. ​(Regulation – 1272/2008 – EN – CLP Regulation – EUR-Lex, 2008)​. 

It is important to note that cosmetic product ingredients are regulated by more than just the EU CPR, they are also regulated by the CLP Regulation and the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) ​(Regulation – 1907/2006 – EN – REACH – EUR-Lex, 2006)​. These regulations directly affect the EU CPR and shouldn’t be overlooked. 

Keeping up with the most up-to-date science allows for a greater understanding of how consumer products affect human health and the environment, however, there are some challenges that the indsutry, regulators and scientists face during the discovery and implementation process. 

Safety Assessment of Substances in Cosmetics 

Scientific bodies such as the SCCS and SAG-CS undergo a four-step safety evaluation procedure which consists of a) hazard identification, b) exposure assessment, dose-response assessment, d) risk characterisation ​(Vieira et al., 2024)​. In this safety evaluation, data from post-market surveillance, intrinsic physical and chemical properties, aggregate exposures, point of departure (PoD), No Observed Adverse Effect Level (NOAEL), and margin of safety (MoS) are all considered. There is a challenge in gathering data points for the assessment of chemical safety due to the introduction of the ban on animal testing methods being used to assess safety. The main challenges come from assessing repeat-dose toxicity, reproductive toxicity, and toxicokinetics as there are currently no animal testing alternatives for ​(Vieira et al., 2024)​. This is a challenge for the scientific community, leading to the development of new approach methodologies (NAMs). 

Legislative Burdens to Cosmetic Brands 

Due to the ongoing new findings on chemical safety in consumer products, legislation has to be updated. This is not intrinsically a legislative burden for companies; however, the short notification to implementation dates can be. The above example of the restriction of silver is a good illustration of a current challenge faced by cosmetic brands and manufacturers. The amendment to regulation was published on the 12th of January 2026, and the effective date for the changes stipulated in this regulation is the 2nd of February 2026 ​(Regulation – EU – 2026/78 – EN – EUR-Lex, 2026)​. This gives companies a very short period of time to comply with the legislative update, in which time companies may need to reformulate or take products off the market to comply with the EU CPR.