What SI 2026/23 actually does, and when
The Cosmetic Products Regulation (EC) No 1223/2009 (Restriction of Chemical Substances) (Amendment and Transitional Provisions) Regulations 2026, SI 2026/23, was laid before Parliament on 15 January 2026. It is made law, not a consultation. Its core provisions come into force on 15 July 2026, with one exception: regulation 2(3), which adds a further batch of substances to the prohibited list, comes into force a month later, on 15 August 2026.
Three nuances that separate signal from noise
01
Two force dates, not one
The Enzacamene ban and the formaldehyde threshold apply from 15 July 2026. The 16 additional CMR substances apply a month later, from 15 August 2026.
02
Great Britain only
SI 2026/23 governs England, Scotland and Wales. Northern Ireland is not covered by this instrument at all.
03
Existing stock gets a runway
Products already placed on the market before the relevant date can still be sold through: this is not an immediate shelf-pull.
15 Jul 2026
Enzacamene (4-MBC) can no longer be placed on the GB market as a UV filter, at any concentration. Formaldehyde-release warning threshold drops from 0.05% to 0.001%.
15 Aug 2026
16 further substances classified CMR category 1B or 2 are added to Annex II: fully prohibited in cosmetic products, regardless of concentration.
14 Jan 2027
Off-shelf deadline: products with Enzacamene or under the old formaldehyde threshold, placed on the market before 15 July 2026, must be cleared by this date.
14 Feb 2027
Off-shelf deadline for the 16 newly listed CMR substances, for stock placed on the market before 15 August 2026.
One country, two cosmetics regimes
SI 2026/23 amends the retained EU Cosmetic Products Regulation as it applies in Great Britain only. Northern Ireland is not part of this instrument: under the Windsor Framework, it continues to follow the EU Cosmetics Regulation directly, including the EU’s own, separately timed batch of CMR restrictions. A brand selling the same SKU across the UK is not managing one ruleset with one deadline; it is managing two, on two different calendars, decided by two different legislators.
Great Britain
Governed by SI 2026/23. Enzacamene banned and formaldehyde threshold cut from 15 July 2026; 16 CMR substances added from 15 August 2026. Set by UK domestic legislation.
Northern Ireland
Governed directly by the EU Cosmetics Regulation (EC) 1223/2009 under the Windsor Framework. Its own CMR restrictions and dates apply: set by the European Commission, not by SI 2026/23.
Why this is a product-data problem, not just a reformulation one
Reformulating out Enzacamene, or the 16 newly restricted CMR substances, is the visible part. The harder part is knowing which SKUs are affected at all. The formaldehyde change is the sharpest example: the labelling trigger drops by a factor of 50, from 0.05% to 0.001%: a concentration most formulation records were never built to track at that resolution. A brand needs, per SKU, the exact release concentration of every formaldehyde-releasing preservative it uses, not just a pass/fail against the old threshold.
Layer the GB/Northern Ireland split on top, and “UK” stops being a valid row in a compliance tracker. The same SKU needs a market flag, GB or NI, mapped to two different substance lists and two different deadlines, kept current as each legislator moves independently. That mapping, per product and per market, updated as the rules change on their own separate clocks, is exactly the discipline Cleo’s engine MARIA is built to hold.
Frequently asked questions
Does the UK's new cosmetics ban apply across the whole United Kingdom?
What exactly changes on 15 July 2026, and what changes on 15 August 2026?
Can brands still sell existing stock that contains Enzacamene or the newly banned CMR substances?
Sources
- legislation.gov.uk: The Cosmetic Products Regulation (EC) No 1223/2009 (Restriction of Chemical Substances) (Amendment and Transitional Provisions) Regulations 2026 (SI 2026/23)
- UK Parliament: Statutory Instruments tracker, SI 2026/23
- CIRS Group: UK to ban 4-MBC and 16 CMR substances in cosmetics, and lower labelling threshold for formaldehyde-releasing substances
- Mishcon de Reya, UK and EU cosmetics regulations: what beauty businesses need to know about 2026 updates
