Great Britain’s SAG-CS adopts a different position from the EU on silver

On 21 August 2026, the Great Britain’s (GB) Scientific Advisory Group on Chemical Safety (SAG-CS) issued seven new safety opinions covering ingredients used in cosmetic products.

Opinions aligned with the EU framework

For six of the substances evaluated, the SAG-CS reached conclusions that are in alignment with previous assessments by the EU Scientific Committee on Consumer Safety (SCCS) and with the restrictions already reflected in the EU Cosmetics Regulation.

Triclocarban

The SAG-CS concluded that triclocarban is safe when used at up to 1.5% in rinse-off products intended for adults, and at up to 0.2% when used as a preservative in cosmetic products, with the exception of mouthwashes for all age groups and toothpastes intended for children.

These conditions are already reflected in the EU regulatory framework following the adoption of Commission Regulation (EU) 2024/996.

Sodium Orthophenylphenate (SOPP)

According to the SAG-CS opinion, sodium o-phenylphenate (SOPP) may be used as a preservative at concentrations of up to:

  • 0.2% in rinse-off products
  • 0.15% in leave-on products

Oral care products and spray applications are excluded from the assessment.

As no data on children’s exposure were presented for either this ingredient or OPP, the safety of use in this age group was not assessed.This conclusion is in alignment with the position previously adopted by the SCCS and implemented in the EU through Commission Regulation (EU) 2018/1847.

Triclosan

The SAG-CS considered triclosan safe when used as a preservative at:

  • 0.2% in mouthwashes
  • 0.3% in toothpastes
  • 0.3% in hand soaps, shower gels, deodorants (non-spray), face powders, blemish concealers, and nail-cleaning products used before artificial nail applications

These concentration limits mirror those already applicable in the European Union.

Daidzein

The SAG-CS concluded that daidzein is safe for cosmetic use at concentrations of  0.02%.

The same restriction is already included in the EU Cosmetics Regulation and has applied since 2025.

Orthophenylphenol (OPP)

For orthophenylphenol, the SAG-CS concluded that use is acceptable at a maximum concentration of:

  • 0.2% in rinse-off products
  • 0.15% in leave-on products

When orthophenylphenol and sodium orthophenylphenate are used together, their combined concentration should not exceed these limits.

As with the SOPP opinion, oral care products and spray applications were not included in the assessment. The opinion aligns with the SCCS position already implemented in the EU.

Resorcinol

The SAG-CS concluded that resorcinol is safe when used under the existing label conditions already required by UK legislation and at the following concentrations:

  • Up to 1.25% in oxidative hair dyes and eyelash colouring products (on-head concentration)
  • Up to 0.5% in hair lotions and shampoos

These limits correspond to those already found in Entry 22 of Annex III to the EU Cosmetics Regulation.

New GB divergence from the EU: micron-sized silver

The most notable opinion concerns micron-sized silver, where the SAG-CS diverges from the current EU framework.

The UK committee concluded that micron-sized particulate silver may be used at:

  • 0.3% in leave-on products (excluding lip products). This is in alignment with the EU limit of 0.3% for leave-on products. However, the EU restriction does not exclude lip products from this category
  • 0.2% in lip products. This concentration corresponds to the limit currently established in the EU for rinse-off cosmetic products
  • 0.3% in rinse-off products (excluding mouthwashes and toothpastes). This is higher than the concentration permitted in the EU, where the limit is set at 0.2%
  • 0.05% in mouthwashes and toothpastes.

The Great Britain approach also differs from the EU framework in additional aspects. The SAG-CS opinion does not establish a dedicated limit for oral hygiene products as a category. In the EU, silver is permitted in oral-care products at concentrations of up to 0.2%, with a lower limit of 0.05% applying specifically to mouthwashes intended for children. By contrast, the SAG-CS applies the 0.05% limit to both mouthwashes and toothpastes intended for all age categories.

In addition, the UK opinion does not provide a specific assessment for nail products. Under the EU Cosmetics Regulation, micron-sized particulate silver is permitted in nail products at concentrations of up to 0.3%.

The opinion does not cover propellant spray products, as these uses were not included in the data submitted for assessment.

Why is this important?

Silver has been in the spotlight of the EU cosmetic industry for the past months.

In the EU, micron-sized particulate silver was initially heavily restricted following concerns raised in an earlier SCCS assessment. As a result, Omnibus Act VIII limited its use largely to oral-care products and certain colourant applications.

However, new dermal penetration studies submitted in 2025 led the SCCS to revise its assessment. Based on these new data, the SCCS concluded in 2026 that micron-sized silver does not penetrate the skin and may be considered safe at concentrations of up to 0.2% in rinse-off products and 0.3% in leave-on products, except for applications that could result in inhalation exposure, such as certain spray products. Following this reassessment, the European Commission moved to amend the existing restrictions and substantially broaden the permitted uses of silver across a wider range of cosmetic products.

Despite this regulatory evolution, the UK SAG-CS opinion does not mirror either the previous EU restrictions or the most recent EU amendment. Notably, GB allows a higher concentration in rinse-off products (0.3% versus 0.2% in the EU), ittakes a different approach to oral-care products and other product categories, and it does not differentiate between products for children versus products for adults.

As a result, silver becomes another example of the growing divergence between the GB and EU cosmetics regulatory frameworks.

Do you have questions on how to sell your cosmetics in the UK? Contact us here or write an email to COSlaw@obelis.net.

References

European Commission. (2024). Commission Regulation (EU) 2024/996 amending Annexes II, III, V and VI to Regulation (EC) No 1223/2009 on cosmetic products. Retrieved on 08/09/2026.

European Commission. (2018). Regulation (EU) 2018/1847 amending Annex V to Regulation (EC) No 1223/2009 on cosmetic products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 20: Triclocarban in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 21: Sodium Orthophenylphenate in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 22: Triclosan in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 23: Daidzein in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 24: Orthophenylphenol in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 25: Resorcinol in Cosmetic Products. Retrieved on 08/09/2026.

SAG-CS. (2026). Opinion 26: Silver in Cosmetic Products. Retrieved on 08/09/2026.

SCCS. (2026). Scientific Advice on Silver used in cosmetic products. Retrieved on 24/04/2026.

WTO. (2026). Draft Commission Regulation amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards the use in cosmetic products of silver. Retrieved on 31/07/2026.

WTO. (2026). Draft Annex to the Commission Regulation amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards the use in cosmetic products of silver. Retrieved on 31/07/2026.

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