Regulation (EU) 2026/909: Citral, Zinc Salts and DHHB Limits Cosmetics Companies Must Act On Before 2027

On 27 April 2026, the European Commission adopted Commission Regulation (EU) 2026/909, amending Annexes II, III, V and VI of the Cosmetics Regulation (EC) No 1223/2009 on the basis of recent Scientific Committee on Consumer Safety (SCCS) opinions. Multiple industry summaries report the regulation entered into force on 18 May 2026, revising the conditions of use for roughly a dozen ingredients across the prohibited, restricted, preservative and UV filter lists.

The revision touches ingredients that are genuinely common in formulation: Citral (including its Geranial and Neral isomers), Benzyl Salicylate, several zinc salts used in deodorants and oral care, and the UV filter DHHB (Diethylamino Hydroxybenzoyl Hexyl Benzoate). It also adds new outright prohibitions, including Benzophenone-1, Benzophenone-2, and the colourants Basic Brown 16 and Basic Blue 99. According to the same sources, the general compliance timeline gives companies until 1 January 2027 to place only compliant products on the market, and until 1 July 2028 before non-compliant stock must be fully withdrawn from sale.

This affects formulators and responsible persons working with fragrance compounds, essential oils, deodorants and antiperspirants, sunscreens and UV-filter systems, oxidative hair colourants, and any private-label brand whose supplier formulations have not yet been re-screened against the updated annexes.

What changes under Regulation (EU) 2026/909?

Reporting from multiple regulatory-tracking sources (REACH24H, SGS, Cosmeservice, CosmeticObs) converges on the following changes. As with any multi-annex amendment, the exact wording and per-substance transition provisions should be checked against the consolidated Annex text before formulation decisions are finalised:

• New prohibitions added to Annex II: Benzophenone-1, Benzophenone-2, the colourants Basic Brown 16 and Basic Blue 99, and prostaglandins and their analogues.
• Citral (including Geranial and Neral) receives revised, category-specific concentration limits reflecting an updated skin-sensitisation risk assessment; limits are reported to differ across leave-on, rinse-off, oral and deodorant product types.
• Benzyl Salicylate is similarly revised with category-specific limits rather than a single blanket threshold.
• The restricted zinc salts entry is both expanded and tightened: previously covering zinc acetate, zinc chloride, zinc gluconate and zinc glutamate at a maximum of 1% (as zinc) across all cosmetic types, it now also covers zinc citrate and zinc sulphate, with limits refined by product category and, per the underlying October 2023 SCCS opinion, by age group.
• The UV filter DHHB remains permitted but now carries a stated impurity limit: di-n-hexyl phthalate (DnHexP), an unavoidable trace impurity from synthesis, must not exceed 10 ppm in the raw material.
• One new entry is reportedly added to the list of permitted preservatives; the specific substance was not consistently detailed across the sources reviewed and should be confirmed directly against the regulation text.

Flag for verification: the figures above are compiled from secondary regulatory-tracking summaries, not a direct reading of the Official Journal text, since EUR-Lex was not accessible during research for this article. Before reformulating or updating a CPSR on the basis of any single threshold quoted here, confirm the exact wording of the relevant Annex II, III, V or VI entry in Commission Regulation (EU) 2026/909 as published in the Official Journal.

Revision versus new prohibition: why the compliance date is not the same for every entry

Not every change in this regulation carries the same clock. A revised restriction entry, such as the updated Citral, Benzyl Salicylate or zinc salts limits, typically follows the standard two-step transition used elsewhere in Regulation (EC) No 1223/2009: a first date by which newly placed products must already comply (reported here as 1 January 2027), and a later date by which any remaining non-compliant stock must be off the market entirely (reported as 1 July 2028). A brand-new prohibition, such as Benzophenone-1, Benzophenone-2, Basic Brown 16 or Basic Blue 99, more commonly applies from the regulation’s entry into force with little or no phase-in, since there is no “revised limit” to transition toward, only removal. Treat the 2027/2028 dates as the general case, and check the specific transitional provision attached to each entry rather than assuming one timeline covers the whole regulation.

What counts against the DHHB impurity limit, and how is it tested?

The DnHexP limit targets an unavoidable trace impurity carried over from the synthesis of the DHHB raw material, not an ingredient a formulator adds on purpose. That means the relevant evidence is a certificate of analysis or impurity test on the UV filter raw material itself, generally by GC-MS, from the supplier or an independent laboratory, not simply a declaration on the finished product’s label. A finished sunscreen formulation can only be confirmed compliant if the DHHB raw material batch used in it was tested and shown to sit at or below 10 ppm DnHexP.

What should cosmetics companies check?

1. Screen current formulations for the newly prohibited substances. Confirm that Benzophenone-1, Benzophenone-2, Basic Brown 16, Basic Blue 99 and prostaglandin analogues are not present in any UV-stabiliser, colourant or specialty active raw material used in your supply chain.
2. Re-check Citral and Benzyl Salicylate concentrations against the revised, category-specific limits. Recalculate exposure by product type (leave-on, rinse-off, oral, deodorant) rather than applying a single legacy figure across the whole range.
3. Recalculate zinc content in deodorant, antiperspirant and oral care formulas. Confirm which of the now six listed zinc salts (including the newly added zinc citrate and zinc sulphate) are present, and verify the applicable limit for the specific product category and target age group.
4. Request DnHexP impurity data from DHHB suppliers. Ask for a current certificate of analysis confirming DnHexP content at or below 10 ppm for the specific raw material batch in use, not a general compliance statement.
5. Map every affected SKU against the 1 January 2027 and 1 July 2028 dates. Distinguish new prohibitions, which may apply without a transition period, from revised restrictions, which follow the phased timeline.
6. Update the CPSR, PIF and CPNP notification once reformulation is confirmed. Any change to a restricted ingredient’s concentration or removal of a now-prohibited substance should be reflected across all three documents in parallel.

Common implementation risks

• Assuming a single revised concentration limit applies uniformly, when SCCS opinions typically differentiate by product category and, for zinc, by age group.
• Missing Citral or Benzyl Salicylate present as a natural constituent of essential oils, such as lemongrass or ylang-ylang oil, rather than as a deliberately added fragrance ingredient.
• Treating DHHB impurity testing as a one-time raw material qualification rather than an ongoing per-batch check.
• Confusing the 18 May 2026 entry-into-force date with the 1 January 2027 compliance deadline, and continuing to ship stock formulated to the old limits in between.
• Assuming every entry in the regulation shares the same transition period, when new prohibitions can apply with little or no phase-in unlike revised restrictions.
• Private-label brands relying on a contract manufacturer’s prior formulation sign-off without confirming it has been re-checked against the 2026/909 annex updates.
• No single internal register tracking which of the four amended annexes (II, III, V, VI) affects which product line, making the overall exposure hard to see at a glance.

How Makrolife can support your review of Regulation (EU) 2026/909

• Formulation screening against the newly prohibited and revised restricted substance lists.
• Analytical quantification of Citral, Benzyl Salicylate and zinc salt content by finished product category.
• Impurity testing (GC-MS) of DHHB raw material batches for DnHexP content against the 10 ppm limit.
• CPSR and PIF gap review against the updated Annexes II, III, V and VI.
• Deadline tracking support across the 1 January 2027 and 1 July 2028 milestones, entry by entry.

The goal across all of this is one consistent regulatory record: formula, label and safety file that all say the same thing, and can all be defended together.

Which of your SKUs still contain a substance now restricted under 2026/909?

If your last formulation review predates April 2026, it is worth checking your fragrance compounds, deodorant zinc salts and UV filter systems now, while there is still runway before the January 2027 deadline.

Request an ingredient compliance check against Regulation (EU) 2026/909 from Makrolife Biotech.

Sources

1. REACH24H – EU Regulation (EU) 2026/909: Comprehensive Interpretation of New Cosmetic Ingredient Restrictions
2. SGS – Cosmetics Regulation (EU) 2026/909 Introduces New Restrictions, Prohibitions and Ingredient Conditions
3. Cosmeservice – EU Cosmetics Regulation 2026/909: New Ingredient Restrictions and Deadlines
4. CosmeticOBS – Regulation (EU) 2026/909: new restrictions for 12 cosmetic ingredients
5. UL Solutions – EU Cosmetics Regulation Annexes Amended Based on SCCS Opinions
6. EUR-Lex – Commission Regulation (EU) 2026/909