Since the end of the Brexit transition period on December 31, 2020, the regulatory landscapes of the United Kingdom and the European Union have evolved along increasingly distinct paths. As the UK now operates under its own independent regulatory framework, divergence between the two jurisdictions continues to grow.
Among the many areas of divergence, chemicals and environmental regulations – both of which have a strong impact on the cosmetics sector – exhibit some of the most significant differences.
HSE’s final opinion under Great Britain CLP
On 25 August 2025, the Health and Safety Executive (HSE) published its final opinion on the classification of tea tree oil (TTO) under the Great Britain Classification, Labelling and Packaging (CLP) Regulation.
In this opinion, the HSE decided to remove the classification of tea tree oil as a reproductive toxicant. The revision was based on issues raised during the drafting of the Agency Technical Report, including the need to differentiate routes of exposure and to consider new studies that could impact the overall classification of TTO.
Classification of Tea Tree Oil (TTO) in the European Union
In November 2023, the European Chemicals Agency’s (ECHA) Committee for Risk Assessment (RAC) adopted an opinion classifying tea tree oil as Reproductive Toxicity Category 2 (Repr. 2) under the EU CLP Regulation (Regulation (EC) No 1272/2008).
Following this potential reclassification, the Scientific Committee on Consumer Safety (SCCS) issued an opinion on the safe use concentrations of tea tree oil in cosmetic products.
Uses of TTO in cosmetics
Tea tree oil (also referred to as TTO, CAS/EC No. 68647-73-4 / 285-377-1) is known under the INCI name “Melaleuca Alternifolia Leaf Oil.” TTO is reported to have multiple cosmetic functions, including antioxidant, skin conditioning, antimicrobial, and perfuming properties.
While TTO is not specifically restricted or banned under the EU Cosmetic Regulation, it has a long history of use in a variety of beauty products, including hair and skin care and oral formulations.
CLP classification: impact on beauty brands
While the HSE agrees with a number of the hazard classifications for tea tree oil (TTO) under the GB CLP Regulation – including those for skin irritation and skin sensitization – it concludes that a classification for developmental toxicity is not warranted based on the current evidence.
The different assessments may lead to divergences in the permitted concentrations of tea tree oil in cosmetic products between the EU and Great Britan, and may impact the supply chain between Northern Ireland and GB.
At present, tea tree oil is not included in the SAG-CS workplan.
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References
HSE. (2025). GB CLP – Article 37 – Agency Opinion on the classification and labelling of Melaleuca alternifolia, ext. [1], Melaleuca alternifolia, essential oil; tea tree oil [2] . Retrieved on 26 August 2025.
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