Two deadlines land on cosmetics labels within a month of each other this summer. From 15 July, any product releasing formaldehyde above 0.001% needs an explicit warning, fifty times stricter than the previous threshold, and from 15 August sixteen newly banned substances can no longer be placed on the market at all. For cosmetics labels, that means both a wording change and, in some cases, a full reformulation.
This article sets out what each deadline actually requires and how to tell which one applies to a given product.
What the Formaldehyde Change Requires
The formaldehyde threshold change affects any product using formaldehyde releasing preservatives, common in a wide range of skincare, haircare and personal care formulations. The legal test has moved from whether a product contains formaldehyde to whether it releases it above 0.001% in the finished product, a distinction that catches formulations previously considered compliant under the old 0.05% threshold. Products already on the market before 15 July have until January 2027 to be relabelled or withdrawn, giving businesses a defined window rather than an immediate recall requirement.
What the August Substance Ban Requires
The August deadline works differently. Sixteen CMR substances, alongside the UV filter 4-MBC, cannot be placed on the market from 15 August, with no warning label route available. A formulation containing one of the newly banned substances must be reformulated or withdrawn, not simply relabelled, since this is a substance restriction rather than a disclosure requirement. Products already in circulation have until February 2027 to be sold through, but nothing placed on the market after 15 August can legally contain the banned substances regardless of labelling.
What This Means for Cosmetics Labels
Distinguishing between the two deadlines matters because they demand different responses. A product only affected by the formaldehyde threshold needs a label and warning statement review. A product containing a banned CMR substance needs a reformulation project, which typically takes considerably longer to complete safely. Businesses that have not yet audited their full range against both lists risk discovering a reformulation need much closer to the August deadline than is comfortable.
One Deadline Needs a New Label, the Other Needs a New Formula
Discussion among cosmetics compliance teams has increasingly focused on how many businesses initially treated both dates as a single event, only to realise closer to July that the formaldehyde and CMR changes require genuinely different responses. There is also visible concern among smaller brands without dedicated regulatory teams, several of whom are still confirming which of their products are affected at all.
Confusing the two deadlines is the single most costly mistake a cosmetics brand can make this summer. A business that discovers its August obligation is a reformulation, not a relabel, with only weeks left on the clock, is in a far worse position than one that checked both lists in July and planned accordingly.