New UK restriction on methyl salicylate in cosmetics

On 16 January 2025, the United Kingdom formally notified the World Trade Organization (WTO) of an amendment to Annex III of its cosmetics regulation, introducing new restrictions on the use of methyl salicylate.

The updated regulation follows a March 2024 opinion published by the UK’s Scientific Advisory Group on Chemical Safety (SAG-CS).

Update from April 2025: on 1 April 2025, the amendment was officially published by the UK government.

Key differences from EU restrictions

The UK’s restrictions on methyl salicylate differ from those outlined in the EU Cosmetics Regulation. This marks the second instance of active regulatory divergence by the UK, following its earlier restrictions on butylated hydroxytoluene (BHT).

The main distinctions between the current UK and EU Annex III entries for methyl salicylate are:

Specific age-based restrictions: in certain categories, the UK imposes distinct restrictions for products intended for children aged 6 months to 1 year, whereas the EU does not permit the use of this ingredient in products intended for children under 6 years of age except for toothpaste.
Distinction between limits for aerosol hair products: the UK sets the concentration for all aerosol hair products at 0.009%. Conversely the EU sets different limits between leave-on aerosol hair products (0.009%) and rinse-off hair products 0.06% (incl. aerosol hair products).
Variation in toothpaste limits: in the EU, toothpaste containing methyl salicylate may have a maximum concentration of 2.52%, whereas the UK limits this to 2.5%.
Variation in mouthwash limits: the UK sets the concentration for mouthwash intended for children above 10 years of age and adults at 0.4%, whereas the EU sets it at 0.6%.

Deadlines for compliance

Cosmetic products containing methyl salicylate placed on the market on or before 30 September 2025 may be made available until 31 March 2026.

New SCCS opinion on methyl salicylate and children

On 17 January 2025, the Scientific Committee on Consumer Safety (SCCS) released a revised opinion on children’s exposure to methyl salicylate. While this opinion does not hold legal validity, this development could prompt an amendment to the EU restrictions on methyl salicylate and a closer alignment between EU and UK.

According to the SCCS, the concentration of methyl salicylate should not exceed:

0.45% in toothpaste for children aged 0-3
0.02% in other products for children aged 0-3 years.

If adopted into EU regulations, the new restrictions would slightly differ from the UK’s approach.

Do you have any questions on compliance of cosmetics in the EU, UK, US, or Canada? Contact us here and write an email to COSlaw@obelis.net.