European Economic AreaCosmetic Products Regulation

EU Cosmetics Simplification Proposal Could Prolong Exposure To Carcinogens

A draft European Parliament report linked to the EU’s Chemicals Omnibus could extend transition periods for newly classified carcinogens in cosmetics well beyond today’s 18-month baseline, drawing criticism from health NGOs.

Dr Steven Brennan

2 min readAI-drafted, expert reviewed

Cosmetic containers on a laboratory bench

A proposal under discussion in the European Parliament as part of the EU’s “Chemicals Omnibus” is drawing criticism from health advocates, who argue it could weaken long-standing protections against carcinogenic substances in cosmetics and personal care products. In particular, a draft report would allow some substances newly classified as carcinogenic to remain on the market for up to 6.5 years, compared with a current 18-month limit highlighted by the Health and Environment Alliance (HEAL).

Longer Transition Periods Could Reshape Reformulation Timelines

From an industry perspective, longer transition periods can reduce the risk of sudden product withdrawals, especially for smaller manufacturers managing reformulation and supply chain change. However, critics argue the same flexibility could translate into extended consumer exposure after risks are formally recognised.

HEAL pointed to the scale of routine exposure, citing figures from a related briefing that women use an average of 16 cosmetic products daily, pregnant women 18, and children under three around six. The briefing warns that extended transition periods, combined with restrictive definitions of “suitable alternatives”, could leave carcinogenic, mutagenic and reprotoxic (CMR) substances on the market for years after classification is initiated.

Scope And Exemptions Are Also Under Scrutiny

Beyond timelines, HEAL argued the draft report would narrow restrictions to certain products even where exposure routes such as inhalation or ingestion may be relevant, for example in powders or creams and particularly for children.

The proposal also raises questions about exemptions. HEAL highlighted concerns about broad carve-outs for carcinogens present as constituents of plant-based complex substances, such as essential oils, warning that “natural” origin does not remove hazard.

Compliance Implications For Brands And Suppliers

If Parliament moves towards longer transition periods, cosmetics firms may need to manage a more complex compliance picture, balancing extended sell-through windows with consumer expectations and reputational risk. Ingredient monitoring and supplier assurance processes become more consequential when classification triggers, derogations and product-scope rules may change.

Questions about this change

What is changing in the EU approach to carcinogens in cosmetics?

Under current practice, once substances are newly classified as carcinogenic, restrictions in cosmetics are designed to take effect quickly. The draft report discussed in Parliament would extend transition periods, potentially allowing some newly classified carcinogens to remain on the market for much longer.

What should cosmetics companies do while the proposal is debated?

Companies should stress-test reformulation roadmaps against multiple timeline outcomes, review how they monitor classification updates, and ensure their substantiation for safety and compliance claims remains current. Supplier data sharing and ingredients traceability become more important when timelines and exemptions are in flux.

Dr Steven Brennan

CEO and co-founder of Foresight, and a co-opted member of ECHA's Committee for Socio-economic Analysis. He holds a PhD in chemical engineering.

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