UK Proposes Restrictions on the Use of Benzophenone-3 in Cosmetic Products

On May 8, 2025, the UK Office for Product Safety and Standards (OPSS) under the Department for Business and Trade issued Notification G/TBT/N/GBR/102, proposing the Cosmetic Products (Restriction of Chemical Substances) (No.2) Regulations 2025. The draft regulations seek to amend Annex VI to Regulation (EC) No 1223/2009 (List of UV filters allowed in cosmetic products) to impose restrictions on the use of Benzophenone-3 in cosmetic products. The deadline for submitting comments is 60 days from the date of notification.

Key Amendments

The draft regulations propose revisions to Annex VI "List of UV Filters Allowed in Cosmetic Products" of the UK Cosmetic Regulation (EC) No 1223/2009, specifically concerning:

• in column f (product type, body parts) insert:
  • (a) Face products, hand products, and lip products, excluding propellant and pump spray
  • products;
  • (b) Body products, including propellant and pump spray products;
  • (c) Other products.
• for the text in column g (maximum concentration in ready for use preparation) substitute:
  • (a) 6%;
  • (b) 2.2%;
  • (c) 0.5%.
• for the text in column h (other) substitute:

“For product types (a) and (b), not to be used at more than 0.5% to protect product formulation. If used at 0.5% to protect product formulation, the levels used as UV filter must not exceed 5.5% for product type (a), or 1.7% for product type (b).”

Transitional Provision: Despite the amendments made by regulation 2(2), where a cosmetic product containing 2-Hydroxy-4-methoxybenzophenone/Oxybenzone (Benzophenone-3) is placed on the market on or before January 21, 2026, it may continue to be made available on the market until the end of July 21, 2026.

Regulatory Interpretation

Based on scientific advice from the UK's Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS), this amendment ensures that Benzophenone-3 concentrations in different types of cosmetic products remain at safe levels. In October 2024, SAG-CS issued an assessment opinion on Benzophenone-3 in cosmetics, concluding that its use as a UV filter is safe at the following maximum concentrations:

• Face, hand, and lip products: 6%
• Body products: 2.2%

For more information on UK Cosmetic Regulatory Developments in 2024 and SAG-CS, please cilck here.

About CIRS

The CIRS cosmetic team is dedicated to ensuring that cosmetic products meet stringent global regulatory standards. It can provide one-stop services covering the whole life-cycle of a personal care product, which includes cosmetic ingredient development, physical/chemical tests, toxicological tests (in vivo & in vitro), efficacy studies (in vivo & in vitro), ingredient registration, and product registration.

Our services in the UK include but are not limited to:

• Responsible Person (RP);
• Preliminary review of formula and label;
• Safety assessment;
• Create an accurate PIF;
• Labelling design; and
• SCPN submission.

Further Information

https://members.wto.org/crnattachments/2025/TBT/GBR/25_03205_00_e.pdf