2025 Ingredient Shake Up

One thing I’ve learned in this industry, is nothing is ever set in stone. If you’re still using an SDS you downloaded two years ago, you  might just be navigating uncharted waters. 

2025 brought a fresh round of ingredient restrictions and “absolutely not” lists. And a lot of makers are still working from SDS files that pre date the changes. That’s how you end up compliant in your head and non-compliant in real life. Charming. Expensive and totally  Avoidable.

So what changed?

• EU: tightened the rules on certain ingredients. Some things that were tolerated before are now heavily restricted, reclassified, or pushed out of cosmetics entirely.
• GB: moved in its own direction in places. Not fully aligned, not fully separate. More like “same universe, different timeline”.
• Suppliers: are meant to keep SDS documentation current. In practice, SDS updates tend to happen when someone flags something they simply can’t ignore. Is that ok, no… but it is what it is. 

If you’re imagining your supplier lovingly cross-checking CAS numbers across hundreds of PDFs, I’m genuinely happy you have that level of faith in humanity. But please… open your eyes. 
it’s like one of those expectations vs reality memes. On a regulatory scale. 

Why you should care (if your stomach didn’t do a tiny flip you don’t care enough)

• Your supplier probably doesn’t have a regulatory team. They have Brenda. Brenda is busy. 
• Old stock still exists. Drums bought in 2023 can still be bottled today and sold under the comforting illusion that time stands still. 
• An SDS is not alive. It won’t update itself. It won’t remove newly restricted ingredients. It requires an “oh bugger, I’d better get that one renewed” moment 

It’s a static document. Useful, yes. Psychic, no.

The real problem nobody bangs on about

The ingredients that trip people up are rarely the famous ones. It’s usually the boring whispers hiding in the CAS list:

• stabilisers
• solvents
• photoinitiators
• trace compounds from naturals
• things with names that look like a keyboard sneezed

And because most people don’t read the CAS list, they slide into products like: “don’t mind me, I’m just quietly becoming non-compliant.”

The 2025 watchlist (the “oh bollocks” edition)

EU: ingredients that are getting heavily side-eyed

• TPO (photoinitiator used in nail products) – now very much unwanted in cosmetics in many contexts.
• DMPT – another nail-world menace that keeps cropping up in restrictions and classifications.
• Anything classified as CMR 1A/1B – regulatory kryptonite for cosmetics.

GB: ingredients you need to check properly

• Methyl salicylate (wintergreen) – strict limits and context matter.
• Kojic acid – not a casual “bung it in” ingredient. Precision only.
• CMR restrictions – GB has adopted certain controls that makers miss.

Fragrance chaos 

• Naturals (EOs, resins, botanicals) are getting more scrutiny. “Natural” does not mean “immune”.
• IFRA updates can change the practical usage limits in a way that ruins your day, especially for diffusion heavy products.
• Suppliers reformulate quietly sometimes. If a scent suddenly behaves differently, ask yourself why and fish it with your manufacturer just in case.

NEW: Nine CSS-flagged fragrance ingredients to watch

These are on the “problem children” radar under the Chemical Strategy for Sustainability, with concern around potential moves toward CMR 1B classification.

If anything gets reclassified, it can mean cosmetics become a hard stop, and other categories get seriously awkward. And yes, these can appear in normal fragrance oils. Not niche chemistry. Normal, everyday pours.

The Nine

• Acetophenone (CAS 98-86-2)
• Bourgeonal (CAS 18127-01-0)
• p-tert-Butyltoluene (CAS 98-51-1)
• Cuminaldehyde (CAS 122-03-2)
• Cyclamen Aldehyde (CAS 103-95-7)
• Cyclemax (CAS 7775-00-0)
• Heliotropine / Piperonal (CAS 120-57-0)
• Para Cymene (CAS 99-87-6)
• Tea Tree Oil (CAS 68647-73-4)

Bonus problem: DPO (Diphenyl Oxide). Often self-classified as Reprotoxic 1B and shows up as a backbone ingredient in diffusion-heavy fragrance profiles.

Translation: if these pop up in your CAS list, or a supplier suddenly “updates” a scent with no explanation, don’t shrug it off. These aren’t fringe ingredients. They’re everywhere. Treat it like Lilial déjà vu, only with a bigger reach.

How to avoid accidentally selling illegal moisturiser

Step 1: Stop trusting old SDS files

If it’s older than 2024, assume it might be at least partly out of date until proven otherwise.

Step 2: Email your supplier

“Has this fragrance been checked against the 2025 banned and restricted ingredient updates for the markets I sell in?”

If they reply with:

• “It should be fine”
• “We believe so”
• “We haven’t heard anything about changes”

Read between the lines… they have not checked. They are guessing.

Step 3: If you export to EU or NI, you’ve got double the admin

You may need to meet both GB and EU requirements, even when they disagree. It’s like having two parents with separate rules and both of them are strict.

Lastly (slightly alarming, but useful)

Your suppliers won’t rescue you. Your SDS won’t rescue you. IFRA won’t rescue you. Regulators definitely won’t rescue you.

What rescues you is checking, documenting, and not taking “should be fine” as evidence.

If a fragrance oil feels old, slow-moving, a wee bit different, or quietly reformulated, be suspicious. Polite paranoia keeps you solvent.

This post is guidance, not legal advice. Regulations and classifications change. Always verify against the latest GB and EU requirements for your specific product type, concentration, and market.