On 27 March 2025, the Secretary of State enacted the Cosmetic Products (Restriction of Chemical Substances) Regulations 2025, amending Annex III (List of substances which cosmetic products must not contain except subject to the restrictions laid down) of the UK Cosmetics Regulation (EC) No. 1223/2009, to restrict the use of methyl salicylate in cosmetic products. The amendment has been laid before parliament on 31 March 2025 and will come into force on 30 September 2025. It applies to England, Wales and Scotland.
Amendments to Annex III of the UK Cosmetics Regulation (EC) No 1223/2009
INCI Name | CAS No. | EC No. | Product Type | Methyl Salicylate Usage Restrictions |
Methyl Salicylate | 119-36-8 | 204-317-7 | (a) Rinse-off skin & hair products (except hand wash products) (b) Hand wash products (c) Leave on skin products (except face makeup， spray and aerosol body lotion, spray and aerosol deodorant and hydroalcoholic-based fragrances) and hair products (non-aerosol) (d) Lip products (e) Face makeup products (f) Eye makeup products & makeup remover (g) Toothpaste (h) Mouthwash (i) Mouth spray (j) Hydroalcoholic-based fragrances (k)Deodorant spray and aerosol products (l) Hair products (spray and aerosol) (m) Body Lotion Spray | (a) (1) 0.02% (products intended for children 0.5-1 years) (2) 0.06% (products intended for children above 1 year and adults) (b) (1) 0.02% (products intended for children 0.5-1 years) (2) 0.06% (products intended for children above 1 year and adults) (c) (1) 0.02% (products intended for children 0.5-1 years) (2) 0.06% (products intended for children above 1 year and adults) (d) (1) 0.02% (products intended for children 0.5-1 years) (2) 0.03% (products intended for children above 1 year and adults) (e) 0.05% (f) 0.002% (g) 2.5% (h) (1) 0.1% (products intended for children 6 to 10 years) (2) 0.4% (products intended for children above 10 years and adults) (i) 0.65% (j) 0.6% (k) 0.003% (l) 0.009% (m) 0.04% |
Transitional Provision: Where a cosmetic product containing the substance set out in the Schedule is placed on the market on or before 30th September 2025, it may continue to be made available on the market until the end of 31st March 2026.
Regulatory Interpretation
1. On 16 January 2025, the United Kingdom notified the World Trade Organization (WTO) of its draft regulation titled The Cosmetic Products (Restriction of Chemical Substances) Regulations 2025. This draft proposes to amend Annex III of the Cosmetics Regulation (EC) No 1223/2009 in order to restrict the use of methyl salicylate in certain cosmetic products. Methyl Salicylate has been classified as a CMR(b) substance of category 2 under the EU Classification, Labelling, and Packaging (CLP) Regulation.
2. This amendment aims to ensure that the levels of methyl salicylate in different types of cosmetic products remain within safe limits, in line with the recommendations of the UK Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-GS).
In March 2024, SAG-GS published an opinion on the use of methyl salicylate in cosmetics, concluding that it can be used in cosmetic products, provided that appropriate concentration limits are set based on product categories and target user groups, in order to safeguard consumer safety. For more information on the 2024 developments in UK cosmetics regulations and details about SAG-GS, please refer to:
3. Interpretation of Methyl Salicylate
[Regulatory Requirements in China] The Chinese Cosmetic Ingredient Regulatory Database (ChinaCosIng), independently developed by CIRS Group, indicates that Methyl Salicylate (CAS No. 119-36-8), used as denaturant, flavouring, fragrance, perfuming, masking, oral care or smoothing in cosmetics. Methyl Salicylate has been included in the “Inventory of Existing Cosmetic Ingredients in China (IECIC) (2021 edition)”. The maximum historical usage in leave-on products is 15%.
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