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On 4 November 2025, the UK Health and Safety Executive (HSE) launched a public consultation on its draft recommendation to include three substances in Annex 14 (the Authorisation List) of UK REACH. This is the first time that substances have been proposed for inclusion in the Authorisation List since the UK’s withdrawal from the European Union.

Three Substances Proposed for Inclusion

The three substances prosed for inclusion are:

• 2-ethylhexyl 10-ethyl-4,4-dioctyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (DOTE) (CAS No. 15571-58-1)
• *Reaction mass of DOTE and 2-ethylhexyl 10-ethyl-4-[[2-[(2-ethylhexyl)oxy]-2-oxoethyl]thio]-4-octyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate (MOTE)
• Tetraethyl lead (TEL) (CAS No. 78-00-2)

All three substances are classified as toxic to reproduction under Article 57(c) of UK REACH and are already listed in Annex 14 of the EU REACH Regulation.

Consultation Open Until 4 February 2026

Stakeholders are invited to submit comments by 4 February 2026, providing information specific to Great Britain on current uses, exposure scenarios, possible exemptions, and the availability of safer alternatives. Following the consultation, the HSE will finalise its recommendation and submit it to the UK Secretary of State, and the Scottish and Welsh Ministers for a final decision.

Implications for Industry

Once adopted, authorisation will be required for the use or placing on the market of these substances in Great Britain after the applicable sunset dates, which are expected to be 18 to 24 months after inclusion in Annex 14.

Additional Substances for Future Prioritisation

In parallel, the HSE is inviting interested parties to submit GB-specific information on two further substances to support future prioritisation work:

• Reaction products of 1,3,4-thiadiazolidine-2,5-dithione, formaldehyde and 4-heptylphenol (branched and linear), with ≥ 0.1 % w/w 4-heptylphenol (branched and linear) (several CAS numbers including 1471311-26-8 and 93925-00-9)
• 4,4′-bis(dimethylamino)-4″-(methylamino)trityl alcohol, with ≥ 0.1 % of Michler’s ketone or Michler’s base (CAS No. 561-41-1)

This information will help the HSE prepare future recommendations for inclusion in the Authorisation List.

Access to Consultations and Supporting Documents

All related consultation documents, including the draft recommendation, technical rationale, and background information for both the proposed and future substances, are available on the HSE consultation portal here.

On 31 October, the United Kingdom notified the World Trade Organization (WTO) of a new draft measure titled The Cosmetic Products (Restriction of Chemical Substances) Regulations 2026. Issued by the Department for Business and Trade’s Office for Product Safety and Standards (OPSS), the draft would amend Regulation (EC) No 1223/2009, as retained in Great Britain, introducing stricter controls on several cosmetic ingredients to enhance consumer safety.

Key Proposed Amendments

The draft regulation introduces three main updates:

• Formaldehyde-releasing preservatives: The labelling threshold would be lowered, requiring clearer disclosure for products releasing even small quantities of formaldehyde.
• Ban on 3-(4-Methylbenzylidene)-d1 camphor (4-MBC / Enzacamene): The UV filter would be prohibited in cosmetic products due to potential endocrine and reproductive toxicity concerns.
• Addition of 16 new CMR substances to Annex II: These substances have been classified under the GB CLP Regulation as carcinogenic, mutagenic, or reprotoxic (Category 1B or 2) and will therefore be banned for use in cosmetics.

These additions align Great Britain’s cosmetics framework more closely with recent GB CLP classification updates and reflect ongoing convergence with EU scientific risk assessments where appropriate.

Scientific Basis

The Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS) advised the government on the health risks associated with 4-MBC and formaldehyde-releasing preservatives. SAG-CS concluded that continued use of these ingredients may pose unacceptable risks to consumers, prompting the OPSS to initiate this regulatory update.

Implementation Timeline

The draft regulation is expected to be adopted in January 2026. Most provisions, including the ban on 4-MBC and the revised labelling requirements for formaldehyde-releasing substances, are scheduled to enter into force on 15 July 2026. The amendment introducing the 16 newly classified CMR substances to Annex II of the Cosmetic Regulation will follow one month later, becoming effective on 15 August 2026.

Transitional Provisions

• Products containing 4-MBC or formaldehyde-releasing preservatives placed on the market before 15 July 2026 to remain available until 15 January 2027.
• Products containing any of the newly listed CMR substances placed on the market before 15 August 2026 to remain available until 15 February 2027.

These provisions are intended to give manufacturers time to reformulate affected products and update compliance documentation.

Public Consultation

Comments are invited until 30 December 2025 and should be submitted to the UK TBT Enquiry Point via tbtenquiriesuk@businessandtrade.gov.uk.

The full draft text of The Cosmetic Products (Restriction of Chemical Substances) Regulations 2026 is available here.