Westminster Policy News & Legislative Analysis

GB bans 4-MBC; 0.001% formaldehyde warning from July 2026

Great Britain will ban the UV filter 4‑methylbenzylidene camphor (enzacamene) and lower the labelling trigger for formaldehyde‑releasing preservatives to 0.001% from 15 July 2026. The same Statutory Instrument also prohibits sixteen substances newly classified as carcinogenic, mutagenic or toxic for reproduction and inserts them into Annex II of the retained Cosmetic Products Regulation (EC) No 1223/2009. The Regulations apply in England, Wales and Scotland. According to legislation.gov.uk, the instrument was made on 12 January 2026 and laid before Parliament on 15 January 2026.

In regulatory terms, enzacamene moves from Annex VI (UV filters allowed) to Annex II (substances prohibited). Removing entry 18 in Annex VI ends its permitted use as a UV filter in cosmetic products in Great Britain. The Department for Business and Trade states that this responds to sufficient scientific evidence of a potential risk to human health, following advice from the Scientific Advisory Group on Chemical Safety of Non‑Food and Non‑Medicinal Consumer Products.

Annex V’s preamble is amended so that any finished product containing a preservative listed in Annex V that releases formaldehyde must display the warning ‘releases formaldehyde’ where the concentration of formaldehyde in the finished product exceeds 0.001% (10 ppm). This replaces the earlier requirement to state ‘contains formaldehyde’ above 0.05% (500 ppm). The new wording and threshold apply to products placed on the market from 15 July 2026.

The labelling rule applies whether one or several formaldehyde‑releasing preservatives are used; the threshold relates to the total formaldehyde released in the finished product. Products lawfully placed on the market before 15 July 2026 may remain available through to the end of 14 January 2027 if labelled in line with the pre‑existing requirement.

Schedule 2 adds sixteen substances to Annex II following GB CLP classifications in categories 1B or 2. These are diphenyl(2,4,6‑trimethylbenzoyl)phosphine oxide (TPO), clothianidin, dimethyl propylphosphonate, dibutyltin maleate, dibutyltin oxide, tetrabromobisphenol‑A, 1,4‑benzenediamine N,N’‑mixed phenyl and tolyl derivatives, 4‑methylimidazole, acetone oxime, benthiavalicarb isopropyl, 2,3‑epoxypropyl neodecanoate, specified multi‑walled carbon nanotubes, 7‑oxabicyclo[4.1.0]hept‑3‑ylmethyl 7‑oxabicyclo[4.1.0]heptan‑3‑carboxylate, 2‑(dimethylamino)‑2‑[(4‑methylphenyl)methyl]‑1‑[4‑(morpholin‑4‑yl)phenyl]butan‑1‑one, S‑metolachlor and trimethyl borate. In practice, TPO is the entry most likely to appear in cosmetic formulations, notably some UV‑cured nail systems.

From 15 August 2026, no cosmetic product containing any of these sixteen substances may be placed on the GB market. Products placed on the market before that date may continue to be made available until the end of 14 February 2027.

For compliance planning, ‘placing on the market’ in GB law means the first supply of a product in the market. ‘Making available’ covers any subsequent supply, including retail and professional channels. The sell‑through dates therefore apply to unsold retail stock and to products supplied to salons.

Responsible Persons should remove 4‑methylbenzylidene camphor from GB formulations, check raw materials for formaldehyde‑releasing preservatives, and confirm expected released‑formaldehyde levels in finished products against the 0.001% trigger. Labels and artwork should be updated to use the phrase ‘releases formaldehyde’ where required. Where UV‑cured nail gels are supplied, any use of TPO should be reviewed and discontinued for GB products.

Product Information Files should capture reformulations, labelling decisions and supporting supplier data. Where reformulation cannot be completed by the placing deadlines, firms should plan depletion strategies to meet the off‑shelf dates, including arrangements for returns from retail if necessary. Importers and distributors should ensure stock entering GB after the placing deadlines complies with the amended Annexes.

The Regulations extend to England, Wales and Scotland. Businesses supplying Northern Ireland should note that NI continues to follow the EU Cosmetics Regulation. The EU labelling trigger for formaldehyde at 0.001% already applies and enzacamene is not permitted as a UV filter under EU rules; firms operating across GB and NI may wish to standardise to the stricter position.

The change to formaldehyde labelling reflects advice from the UK Scientific Advisory Group on Chemical Safety issued in May 2025, which recommended a 0.001% threshold to better protect sensitised consumers. Industry bodies have also flagged the need for clear supply‑chain statements on formaldehyde release from Annex V preservatives to support label decisions.

Key dates are 15 July 2026 for the 4‑MBC ban and the revised formaldehyde labelling requirement, and 15 August 2026 for the CMR additions to Annex II. Sell‑through ends on 14 January 2027 for products placed before 15 July 2026, and on 14 February 2027 for products placed before 15 August 2026. An Explanatory Memorandum is available on legislation.gov.uk; no full impact assessment has been produced.