New EU Restrictions on Citral, Benzyl Salicylate and the UV Filter DHHB

Spectra Cosmetic Compliance

These restrictions are part of Regulation (EU) 2026/909 (Omnibus 2). Confirm current detail for your specific products.

The context: Omnibus 2

Omnibus 2 is an EU amendment revising the rules for around a dozen ingredients, following SCCS opinions on their safety. While the triphenyl phosphate ban is the headline, the amendment's restrictions on common fragrance materials and a UV filter arguably affect a broader range of products, because these ingredients are so widely used across cosmetics.

Unlike an outright ban, these are restrictions the substances remain permitted, but subject to conditions such as maximum concentrations or specific requirements. This means the response is usually to adjust use levels or comply with conditions, rather than to remove the ingredient entirely.

Citral, Geranial and Neral: New Fragrance Allergen Limits Under Omnibus 2

Citral is a widely-used fragrance ingredient, valued for its fresh, lemon like scent, and is made up of two isomers: geranial and neral. Omnibus 2 introduces restrictions on citral following SCCS assessment, addressing the levels at which it can be considered safe under Regulation (EC) No 1223/2009. It's also one of the recognised fragrance allergens that must be declared on labels when present above the relevant threshold, per the EU Cosmetics Regulation labelling rules.

For brands, this means checking citral levels in fragranced products against the new restriction. Because citral is a common component of both fragrance compositions and essential oils particularly citrus and lemongrass-type materials it appears across a wide range of products, so this restriction has broad reach.

Benzyl salicylate

Benzyl salicylate is another common fragrance ingredient, used both for its own mild scent and as a fixative. Omnibus 2 introduces restrictions on its use following an SCCS opinion that identified a potential risk above certain concentrations. Like citral, it is also a declarable fragrance allergen.

Brands using benzyl salicylate need to check their use levels against the new conditions. As with citral, its widespread use as a fragrance material means many products may contain it, so it warrants a portfolio check rather than an assumption that it is not present.

The UV filter DHHB

DHHB diethylamino hydroxybenzoyl hexyl benzoate is a UV filter used in sunscreens and SPF products. Omnibus 2 addresses DHHB, with attention to matters such as impurity control. For brands making sun care or SPF products using DHHB, this means ensuring their use of the filter meets the updated requirements.

UV filters are, as a category, subject to close and evolving regulation, and DHHB's treatment in Omnibus 2 is part of that ongoing review. Sun care brands should confirm that their DHHB containing products comply with the amendment's requirements ahead of the deadlines.

The deadlines

As with the rest of Omnibus 2, the general position is that non-compliant products cannot be placed on the EU market from 1 January 2027, or made available from 1 July 2028. Certain substances have their own timelines notably, the making available deadline for specific citral isomers (geranial and neral) is extended to 1 August 2028. Brands should apply the correct deadline to each affected substance.

Because the deadlines are staggered and substance specific, it is important to identify exactly which restrictions affect which products and to track the relevant date for each. A single product containing more than one affected substance may need to satisfy more than one requirement.

What brands need to do

The practical steps are to identify products containing citral, benzyl salicylate or DHHB, check whether each still complies under the new restrictions, and adjust use levels or conditions where needed ahead of the deadlines. Because these are restrictions rather than bans, compliance may often be achieved by reducing a level rather than removing the ingredient though that depends on the specific requirement.

Where levels change, or the allergen declaration is affected, the product's CPSR, PIF and label may need updating. For fragranced products, this is also a reminder to keep allergen data current, since citral and benzyl salicylate are declarable allergens. Our allergen review service can help work this through.

Keeping fragrance compliance current

The citral and benzyl salicylate restrictions are a reminder that fragrance compliance is a moving target. These are among the most common fragrance materials in cosmetics, and both are also declarable allergens so they sit at the intersection of two evolving areas: substance restrictions and allergen labelling. A brand using them has to keep pace with changes on both fronts.

Practically, this means maintaining good allergen and IFRA data for every fragrance and essential oil, and re checking products whenever the rules change. When a fragrance material is newly restricted, or the allergen labelling list expands, the affected products need reviewing for both their use levels and their declarations. Keeping this data current makes each such review far quicker than starting from scratch.

For brands with fragranced ranges, this is an argument for treating fragrance compliance as an ongoing discipline rather than a one off at launch. The combination of substance restrictions (like these) and the expanding allergen list means fragranced products are among the most frequently affected by regulatory change and the best prepared brands are those that keep their fragrance data organised and current.

Fragrance ingredients under growing scrutiny

The restrictions on citral and benzyl salicylate are part of a wider pattern of increasing regulatory attention on fragrance ingredients. As the science on skin sensitisation and other effects develops, more fragrance materials are being assessed by the SCCS and, where concerns arise, restricted or added to the declarable allergen list. Fragrance is, in short, one of the most actively regulated areas of cosmetic formulation.

For brands, this means fragranced products carry an inherent regulatory sensitivity: they are more likely than most to be affected by the next amendment, whether through a substance restriction or an expansion of allergen labelling. Building products around well characterised fragrances, and keeping detailed allergen and IFRA data on file, is the best way to stay ready for these recurring changes.