EU Regulation 2026/909: The Ingredient Restrictions With 2027 Dates

Short answer: EU Regulation (EU) 2026/909 has been in force since 18 May 2026, restricting several widely used ingredients — citral, benzyl salicylate, water-soluble zinc salts, aluminium-containing ingredients — and prohibiting triphenyl phosphate, with non-compliant products barred from the EU market from 1 January 2027.

While the fragrance-allergen expansion gets the headlines, the 2026/909 restriction package is the change most likely to force actual reformulation. It touches preservative-adjacent fragrance materials, deodorant-relevant zinc salts and antiperspirant-relevant aluminium chemistry — which means several entire product categories have dated homework. Here is the structure and the checklist.

What the regulation does

Regulation (EU) 2026/909 amends the annexes of Cosmetics Regulation 1223/2009. Its two modes:

• Restrictions — named substances may continue but only under conditions (lower limits, specified uses), effectively rewriting several ingredient entries.
• Prohibition — triphenyl phosphate, a film-former historically used in nail products and some leave-ons, is banned.

The named restricted group most relevant to everyday manufacturing: citral (with its isomers geranial and neral given dates of their own), benzyl salicylate (a fragrance material), water-soluble zinc salts (relevant to deodorant and care formats) and aluminium-containing ingredients (the antiperspirant actives and their relatives).

The key dates

As with the allergen expansion, the operative word is placed: the obligation attaches at market entry, not at manufacture. Stock produced in late 2026 for a February 2027 placement needs the compliant formula and label.

The category impact map

• Fragranced products. Citral and benzyl salicylate are fragrance-palette materials as well as named allergens. A fragrance compound that was compliant in January 2026 may need a rebalance — and since the allergen expansion (our EU fragrance allergen guide covers those dates) is also in its transition window, many fragrance houses are reissuing compounds once, covering both rules.
• Deodorants and body care. Water-soluble zinc salts face new conditions; formats built on them need a reformulation or a substitution review now, not in December.
• Antiperspirants. Aluminium chemistry is restricted under new conditions — this is the highest-stakes line in the package for brands whose core volume is antiperspirant.
• Nail and long-wear products. The triphenyl phosphate prohibition removes a film-forming option; affected nail formulas need a replacement film-former and a re-verification pass.
• Everything aluminium-adjacent. Toothpaste-class and other aluminium-containing formats inherit conditions that need checking line by line.

Compliance checklist for brands selling into the EU

1. Screen every formula against the 2026/909 entries — not just the four headline names; the annex amendment carries conditions that matter.
2. Get the fragrance compound's updated declaration covering both this regulation and the allergen expansion in one document.
3. Decide reformulate vs. substitute vs. drop per SKU, in that order of preference — and start the stability verification for any reformulated product immediately, because the verification clock starts at formula freeze.
4. Plan the transition stock against the dates: compliant product can be placed from day one; non-compliant stock already placed sells through to mid-2028, but anything new after 1 January 2027 must comply.
5. Re-check the documentation chain — the CPNP notification and safety assessment must reflect the reformulated formula; annex changes are exactly when PIF contents and reality diverge silently.
6. Coordinate label updates with the allergen relabeling if both apply to the same SKU — one artwork cycle, one printer run.

The most common wrong assumptions

• "My product has no fragrance, so citral doesn't apply." Citral arrives via essential oils too. Botanical extracts are a delivery route for restricted materials, not an exemption.
• "Restrictions equal bans." Most entries are conditional — limits and use cases. The work is reading the condition, not panic-deleting the ingredient.
• "1 January 2027 is the deadline." It is the placement deadline. Production planning, component ordering and stability verification all need to finish before it, which puts the real working deadline in the second half of 2026.
• "The EU will notify me." Nothing notifies you. The importer and Responsible Person own this — and for OEM buyers, that means your manufacturer's formula documentation is where compliance is proven or lost.

FAQ

Q: What is EU Regulation 2026/909? A: It is the 2026 amendment to the EU Cosmetics Regulation annexes that restricts several ingredients — including citral, benzyl salicylate, water-soluble zinc salts and aluminium-containing ingredients — under new conditions, and prohibits triphenyl phosphate. It has been in force since 18 May 2026.

Q: When must my products comply? A: Non-compliant products cannot be placed on the EU market from 1 January 2027, and sell-through ends 1 July 2028 (1 August 2028 for the citral isomers geranial and neral). Because placement is the trigger, reformulation and verification work needs to complete during 2026.

Q: Does the citral restriction affect fragrance-free products? A: Possibly — citral occurs naturally in essential oils and botanical extracts, so it can be present without added fragrance compound. Compliance is determined by the substance's presence and level, not by how the product is marketed.

Q: Is triphenyl phosphate banned everywhere? A: It is prohibited in cosmetics under this EU regulation, which removes it as an option for EU-market products — most notably in nail and long-wear formats where it was historically used. Affected formulas need a replacement film-former and re-verification.