What formaldehyde warning change means for shared formulas

Commission Regulation (EU) 2022/1181 rewrote the labelling rule for preservatives that release formaldehyde. The scientific committee for consumer safety had concluded that the old threshold of 0.05 percent was insufficient to protect people already sensitised to formaldehyde from contact dermatitis. Sell through for products carrying the old wording closed on 31 July 2026, when full compliance became mandatory.

From that date, any finished cosmetic product sold in the EU where total released formaldehyde exceeds 0.001 percent, or 10 ppm, must carry the words releases formaldehyde. The previous trigger sat fifty times higher, at 0.05 percent or 500 ppm. For a reader who checks for diazolidinyl urea, DMDM hydantoin or sodium hydroxymethylglycinate, the shift is practical. A cream that once passed without a warning may now need one.

The same deadline brought a second label change. 31 July 2026 was the date for placing on the market products that meet the expanded fragrance allergen list under Regulation (EU) 2023/1545. Stock already on the market before that date may still be made available until 31 July 2028.

The choice for brands that sell one formula in both regions is binary. Keep a formaldehyde releasing system and add the warning to shared packs, even for jars sold in the United States, or remove the releaser and rebuild preservation with new testing and sourcing. Plant extracts do not escape the question. A botanical toner with rose water or a tea infusion still needs protection against yeast and mould once water enters the bottle.

Other EU ingredient rules moved on nearby dates. Commission Regulation (EU) 2026/78 applies from 1 May 2026 and replaces Annex V entry 7 to add Sodium o-Phenylphenate alongside o-Phenylphenol with a combined limit, following an opinion of 25 October 2024. The same regulation added fifteen substances classified as carcinogenic, mutagenic or toxic for reproduction to the prohibited list, with no transitional period. Trimethyl borate and N,N’-methylenediacrylamide were prohibited from that May date with no sell through.

Further changes sit ahead. Commission Regulation (EU) 2026/909 was published on 28 April 2026. For many affected products, non compliant goods may no longer be placed on the market from 1 January 2027, with remaining stock to clear by 1 July 2028.

In the United States there is no federal ban on PFAS in cosmetics. The Modernization of Cosmetics Regulation Act directed the Food and Drug Administration to assess PFAS in cosmetics and publish a safety report by 29 December 2025. State rules now carry more weight. Minnesota required manufacturers to report intentionally added PFAS, with the initial deadline extended to 1 July 2026. Connecticut requires reporting and labeling for cosmetics and other goods from 1 July 2026.

What to watch is the pack in hand. A US label that suddenly states releases formaldehyde does not mean formaldehyde was added as such. It means the finished product exceeds 10 ppm of released formaldehyde. The warning is aimed at protecting already sensitised consumers, not at declaring all low level exposure unsafe for all users. It is not known which specific US products exceed that level.

Read the back label slowly, then decide by skin history rather than fear. If formaldehyde sensitivity is known, the new warning and longer allergen list make avoidance simpler.