1. Role of the SAG-CS: The UK’s Scientific Oversight

The UK established the Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS) to assess the safety of substances in cosmetics, mirroring the EU’s Scientific Committee on Consumer Safety (SCCS). 

The SAG-CS advises the UK government on ingredient bans and restrictions, setting a precedent for regulatory divergence. While initial differences were characterized by delayed EU restrictions, the UK has now implemented its own distinct regulations, demonstrating active divergence. 

2. Key Divergences in Ingredient Restrictions

Methyl Salicylate 

• In March 2024, the SAG-CS issued its opinion on Methyl Salicylate, a common ingredient in fragrances and oral care products. 

• The UK introduced stricter concentration limits for children’s and adolescents’ products compared to the EU. 

BHT (Butylated Hydroxytoluene) 

• The UK imposed unique restrictions on BHT, prohibiting its use in leave-on oral care products, a category not covered under EU rules. 

CMR Substances 

• As of October 3, 2024, the UK banned 65 Carcinogenic, Mutagenic, or Reprotoxic (CMR) substances under its GB CLP Regulation. 

• While the list aligns with the EU’s Omnibus Acts V, VI, and VII, the UK allows some chemicals not classified as CMR under GB CLP but banned by the EU. 

3. Environmental Regulations: Scotland’s Plastic Ban

Scotland is taking bold steps with a ban on plastic-containing wet wipes, effective April 2026. This includes single-use wet wipes in personal care products like baby wipes, facial wipes, and sheet masks. 

This initiative highlights the UK’s focus on reducing plastic waste and is part of a broader trend likely to expand across the region. 

4. Additional Compliance Requirements

Labelling Requirements 

• UK labels must specify the country of origin, e.g., “Made in [Specific Country]”, as the general label “Made in the EU” is not accepted. 

• The UK offers an extended transition period until December 31, 2027, for labelling compliance. 

Safety Assessors 

• UK safety assessors must hold a diploma from a UK university or an equivalent recognised by the UK. 

• While the UK accepts EU qualifications, the EU does not reciprocate this recognition. 

5. Key Takeaways for Cosmetics Manufacturers

Appointing Responsible Persons in Both Regions 

Manufacturers must designate a Responsible Person (RP) in both the EU and UK to comply with local regulations. Having representation in only one region is insufficient. 

Adapting to Diverging Frameworks 

Stay updated on regulatory changes, such as ingredient restrictions, labelling updates, and sustainability requirements.