Spectra Cosmetic Compliance
This amendment operates through the annexes of the EU Cosmetics Regulation. Note: regulatory detail can change, so confirm the current position for your specific products.
What Omnibus 2 is
Regulation (EU) 2026/909, published in the Official Journal on 28 April 2026, amends the annexes of Regulation (EC) No 1223/2009 to update the rules on a set of cosmetic ingredients. Industry calls it "Omnibus 2" or "Omnibus Act 2", because it deals with multiple substances in one instrument, following recent scientific opinions from the Scientific Committee on Consumer Safety (SCCS).
These Omnibus amendments are the EU's main mechanism for keeping ingredient rules current under the wider cosmetics regulations framework. Each one typically reflects new hazard classifications and safety assessments, turning them into binding restrictions. Omnibus 2 is one of the more substantial recent examples affecting fragrance ingredients, a UV filter, preservatives, hair dyes, and more.
The headline: triphenyl phosphate banned
The most prominent change is the prohibition of triphenyl phosphate (TPhP), a substance used as a plasticiser mainly in nail products, which is added to Annex II (prohibited substances). The SCCS was unable to conclude that it was safe, citing insufficient data to rule out potential genotoxicity, so it has been banned outright one of the clearer examples of banned and restricted substances under this amendment.
Because triphenyl phosphate is added to Annex II, products containing it will require full reformulation there is no permitted level. Our dedicated guide to the triphenyl phosphate ban covers this change and its deadlines in detail.
Fragrance ingredients restricted
Omnibus 2 tightens the rules on several fragrance ingredients, including benzyl salicylate and citral (and its constituent isomers geranial and neral). These are well-known fragrance materials, and the amendment introduces restrictions or conditions on their use following SCCS assessment of the levels at which they can be considered safe a further set of banned and restricted substances for brands to check against.
For brands using these common fragrance materials, this means checking their use levels against the new restrictions. Our guide to the citral, benzyl salicylate and DHHB restrictions covers the fragrance and UV filter changes specifically.
UV filter, preservatives and other substances
The amendment also addresses the UV filter DHHB (diethylamino hydroxybenzoyl hexyl benzoate), aluminium-containing ingredients and water-soluble zinc salts (with particular relevance to oral care products), acetylated vetiver oil, several hair dye ingredients, and a reclassification affecting a silver-based preservative. In total, the rules for around a dozen substances or substance groups are revised.
This breadth is what makes an Omnibus amendment significant: a single instrument can touch products across many categories fragrances, sun care, oral care, hair colour and more. Few EU ranges are entirely unaffected by an amendment of this scope, which is why brands need to assess it against their whole portfolio.
The deadlines
Omnibus 2 sets phased, differentiated deadlines. As a general position, from 1 January 2027, cosmetic products containing the affected substances and not complying with the new rules cannot be placed on the EU market; and from 1 July 2028, such products cannot be made available on the market. Certain substances have their own timelines for example, the making-available deadline for specific citral isomers is extended to 1 August 2028.
Because the deadlines vary by substance, brands need to identify which changes affect their products and apply the correct deadline to each. Products containing triphenyl phosphate, in particular, will require full reformulation by the placing-on-market deadline. Confirming the exact date for each affected product is essential.
Who is affected
Given its breadth, Omnibus 2 potentially affects a wide range of brands anyone using the restricted fragrance materials, the DHHB UV filter, the affected preservatives or hair dyes, aluminium or zinc compounds, or (critically for nail brands) triphenyl phosphate. Because several of the substances are common, many EU ranges will have at least one affected product.
The only way to know is to assess the amendment against your formulations. A brand cannot assume it is unaffected without checking, given how widely used some of these ingredients are. This is the practical challenge each Omnibus amendment brings: a portfolio-wide review against the new rules.
What brands need to do
The response is a formulation review against Omnibus 2: identify products containing any affected substance, determine whether each still complies under the new restrictions, and plan reformulation (for banned substances like triphenyl phosphate) or adjustment (for newly restricted ones) ahead of the deadlines. Affected products will need their CPSR and Product Information File updated, and labelling requirements revised where necessary, with your Responsible Person confirming every update.
As with any significant amendment, acting early is far better than waiting. The placing-on-market deadline of 1 January 2027 may seem distant, but reformulation, reassessment and relabelling take time, especially across multiple products. Building the review into your regulatory planning now avoids a rush later.
How Omnibus amendments work
Omnibus 2 is one in a series of such amendments, and understanding the pattern helps brands anticipate them. An Omnibus amendment gathers together the regulatory responses to several recent SCCS opinions and hazard classifications, and enacts them in a single instrument revising the annexes. This is more efficient than issuing a separate amendment for every substance, but it means each Omnibus touches many ingredients at once.
The typical trigger is a new hazard classification (for example, a substance being classified as CMR under EU chemicals law) or an SCCS opinion concluding that a substance is unsafe above a certain level, or unsafe at all. The amendment then either bans the substance (adding it to Annex II) or restricts it (setting conditions in Annex III or the relevant annex), with transitional deadlines for compliance and every reformulation should be backed by an updated safety assessment confirming the new formula's consumer safety profile.
Because these amendments recur, brands selling in the EU can expect a steady flow of them, each requiring a portfolio review. Rather than treating each as a surprise, the sensible approach is to monitor the pipeline of SCCS opinions and classifications, which gives advance warning of what a future Omnibus is likely to contain. This turns compliance from reactive to anticipatory.
Not sure which of your cosmetic products are affected by Omnibus 2?
Spectra can review your formulations against the new bans and restrictions, identify affected products and support the compliance work needed for reformulation, CPSR and PIF updates.
Request an Omnibus 2 Review →
References: Commission Regulation (EU) 2026/909 (EUR-Lex); SCCS opinions; Regulation (EC) No 1223/2009 Annexes II–VI. Verified July 2026; confirm current detail before acting. General information only, not legal advice.
