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EU Cosmetics Regulation 2026/909: What US Beauty Brands Need to Review

Key Takeaways

►Annex II and III updates restrict synthetic UV filters and add fragrance allergen concentration limits

►Labeling updated: allergen disclosure thresholds and revised durability indication requirements

►Responsible Person must certify against updated Annex II/III; existing certifications need review

►Transition timelines vary by substance group; some restrictions apply from publication date

The EU published Cosmetics Regulation 2026/909 in May 2026, introducing updated substance restrictions and labeling requirements for cosmetics placed on the EU market. If you sell beauty or personal care products in Europe, review your formulations and label copy before the transition periods close.

70+ Total amendments to EU Cosmetics Regulation since 2009. Source: EU Commission

The regulation amends the EU Cosmetics Regulation (EC 1223/2009) through updates to Annex II (prohibited substances) and Annex III (restricted substances with conditions of use). The headline changes restrict several synthetic UV filters and introduce new maximum concentration limits for certain fragrance allergens, building on the CMR substance restrictions already in force.

Labeling changes are also included: updated allergen disclosure thresholds and a revised requirement for durability indication on products with a shelf life of 30 months or less.

Any brand selling cosmetics in the EU must have a designated Responsible Person, an entity legally established within the EU that takes accountability for regulatory compliance. The Responsible Person is responsible for CPNP notifications, maintaining the Product Information File, and ensuring the product meets all labeling and safety requirements. Regulation 2026/909 updates the technical standards the RP must certify against. If you're using an existing RP for EU cosmetics compliance, confirm they've reviewed your formulations against the updated Annex II and III restrictions.

Transition periods for reformulation vary by substance. Some restrictions apply from publication. Others allow 12-18 months for market withdrawal of non-compliant products. The EU Commission's regulatory timeline document accompanying 2026/909 sets out effective dates by substance group.

The fragrance allergen restrictions in 2026/909 are particularly significant for brands with complex fragrance formulations. Perfumes, scented body care, and hair care brands should assume their formulation needs review against the updated Annex III limits. Do you know whether any of your active ingredients appear on the updated restricted or prohibited lists?

Brands with products already on the EU market need to run their current formulation against the updated restrictions now. New products entering the EU should meet 2026/909 standards from launch.

Expandly helps US ecommerce brands expand into Europe — compliance, marketplaces and fulfilment, all handled. We’ve supported 2,000+ brands make the move.

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The bigger picture

EU cosmetics compliance and the US-EU regulatory gap

EU Cosmetics Regulation amendments are a recurring feature of the European regulatory calendar. The base regulation (EC 1223/2009) has been amended over 70 times through Delegated Regulations and Commission decisions. Regulation 2026/909 is the most recent in a pattern that has progressively tightened restrictions on synthetic fragrances, UV filters, and CMR substances. For US beauty brands, the cumulative effect is that formulations approved for sale in the US are not automatically compliant in the EU. The two regulatory frameworks diverge on ingredient restrictions, labeling requirements, and safety assessment standards. A Responsible Person is the bridge: the entity that takes EU regulatory accountability and ensures the Product Information File, CPNP notification, and formulation documentation all meet EU standards at any given point in time. For US brands entering the EU for the first time, 2026/909 is the current standard, giving brands a clean compliance baseline from the outset.

Brands with complex fragrance formulations in perfumes, scented body care, or hair care should review against updated Annex III allergen limits as a priority
The EUR80 billion EU cosmetics and personal care market represents a material revenue opportunity for US brands with the right compliance structure
CPNP notifications for new products must reference the current regulatory version, which is now 2026/909

Regulation amendments since 2009

The EU Cosmetics Regulation has been amended over 70 times since its adoption in 2009. Each amendment cycle requires Responsible Persons to re-certify formulations against current standards.

70+

EU Commission

EU cosmetics market value

The EU cosmetics and personal care market is worth over EUR80 billion annually, representing a significant commercial opportunity for US beauty brands with the right compliance structure in place.

EUR80bn+

Cosmetics Europe

Compliance-First Onboarding

For beauty brands, Expandly begins with Responsible Person designation and CPNP notification before market setup. From there, VAT registration, marketplace setup and EU-local fulfilment follow in the right order.

2,000+

brands expanded with Expandly

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EU Cosmetics Regulation 2026/909: What US Beauty Brands Need to Review

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Key Takeaways

The bigger picture

EU cosmetics compliance and the US-EU regulatory gap

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