The Lower UK Formaldehyde-Releaser Labelling Threshold Explained

Spectra Cosmetic Compliance

This change is part of SI 2026/23. Confirm the current detail for your specific products, as regulatory positions evolve.

The background: formaldehyde releasers

Some cosmetic preservatives work by slowly releasing small amounts of formaldehyde, which acts as the antimicrobial agent. These "formaldehyde-releasing preservatives" a well-established group of ingredients listed in Annex V of Regulation (EC) No 1223/2009 are effective and widely used, particularly in rinse off and water-containing products. Formaldehyde itself, however, is a known allergen and sensitiser for some people.

Because of this, cosmetic rules have long required a warning on the label when a product releases formaldehyde above a certain level, so consumers sensitive to it can make informed choices. What SI 2026/23 changes, under the UK Cosmetics Regulation, is the level at which that warning is triggered and the wording used.

What has changed

SI 2026/23 makes two linked changes. First, it lowers the warning threshold from 0.05% to 0.001% of free formaldehyde a fiftyfold reduction. Second, it changes the wording of the requirement from products that 'contain' formaldehyde to products that 'release' it, better reflecting how these preservatives actually work. Both changes apply from 15 July 2026 in Great Britain.

The practical effect of the lower threshold is significant: many products that previously fell below the 0.05% warning level will now cross the far lower 0.001% level, and so will need to carry the formaldehyde warning for the first time. It is a substantial expansion of the products affected.

Why the change was made

The change is driven by consumer transparency and protection, particularly for people who are sensitised to formaldehyde. At the previous 0.05% threshold, products releasing lower but still potentially relevant amounts of formaldehyde carried no warning, leaving sensitive consumers without the information to avoid them. The much lower 0.001% threshold captures far more of these products.

This reflects a broader regulatory trend toward greater transparency about allergens and sensitisers in cosmetics the same impulse behind the expansion of fragrance allergen labelling. For formaldehyde sensitive individuals, the lower threshold means many more products will now visibly declare the presence of released formaldehyde.

Who is affected

The change affects any brand using formaldehyde-releasing preservatives in products placed on the Great Britain market where the released formaldehyde exceeds the new 0.001% threshold. Because that threshold is so low, this potentially includes a wide range of products many water-containing and rinse-off products in particular, where these preservatives are common.

It is primarily a labelling and compliance responsibility for brands and Responsible Persons, rather than a ban: the preservatives themselves remain permitted (within their own limits), but the warning must now appear far more often. Brands need to know which of their products use these preservatives and whether they cross the new threshold.

What brands need to do

The first step is to identify products using formaldehyde-releasing preservatives and determine, based on the formulation, whether the released formaldehyde exceeds 0.001%. Where it does, the product's label must carry the required warning using the updated 'releases formaldehyde' wording, in place from 15 July 2026 for the GB market.

This may mean revising label artwork for a number of products, and updating the PIF to reflect the labelling. Some brands may also choose to review whether to continue using formaldehyde-releasing preservatives at all, given the expanded warning requirement, though that is a commercial and formulation decision rather than a legal necessity.

The wording change matters

The shift from 'contains formaldehyde' to 'releases formaldehyde' is more than cosmetic. It more accurately describes what these preservatives do they release formaldehyde gradually rather than containing free formaldehyde as such and it aligns the warning with the way the threshold is assessed (on released formaldehyde). Brands need to use the correct, updated wording, not the old phrasing.

Getting the exact wording right is part of compliant labelling. A product that carries an outdated or incorrect formaldehyde warning is not compliant, even if it correctly identifies that a warning is needed. Confirming the precise required wording for the GB market is therefore important.

The Northern Ireland and EU position

As with the rest of SI 2026/23, this change applies to Great Britain. Northern Ireland follows EU rules under the Windsor Framework, so the formaldehyde labelling position there depends on the EU's requirements, which brands selling in Northern Ireland or the EU should confirm separately.

This is another instance where a UK wide brand must consider both the GB rule and the EU rule that applies in Northern Ireland. Where the two differ, brands may need market specific labelling. Checking the current EU formaldehyde labelling requirement is advisable for products sold beyond Great Britain.

Reviewing your preservative strategy

Because the lower threshold means many more products will now need a formaldehyde warning, some brands are using this as a chance to rethink their preservative strategy more broadly. The question isn't just which products now need the warning it's whether to keep using formaldehyde-releasing preservatives at all, given the wider labelling. That's a commercial and formulation call, not a legal one.

There are good arguments both ways. Formaldehyde-releasing preservatives are effective, well understood, and still permitted within their limits there's no legal requirement to drop them. On the other hand, a visible formaldehyde warning can sit awkwardly with a brand's positioning, especially for products marketed as gentle or for sensitive skin, and alternative preservative systems do exist. The right call depends on each brand's products and market.

Either way, this is a good prompt to think about preservation deliberately, not by default. Switching preservative systems is itself a formulation change it requires reassessment and an updated CPSR and PIF, so it needs proper planning. For many brands, the practical approach is: apply the new labelling where it's required now, and revisit the preservative system next time the product is reformulated.

Part of a wider transparency trend

The formaldehyde change is best understood as one part of a broader move toward ingredient transparency in cosmetics, particularly around allergens and sensitisers. The same impulse lies behind the major expansion of fragrance allergen labelling, which has greatly increased the number of substances that must be individually declared. Regulators in both the UK and EU are steadily raising the bar on what consumers are told about potentially sensitising ingredients.

For brands, the practical implication is that labelling obligations are tending to expand rather than shrink, and staying current means tracking these transparency changes as they arrive. A product’s label is increasingly expected to give sensitised consumers the information they need to avoid what affects them and the formaldehyde threshold change is a clear example of that expectation tightening.