Regulation (EU) 2026/909 has one deadline for placing and four for selling through. Pick the right one.

What the instrument is

Commission Regulation (EU) 2026/909 of 27 April 2026 amends Regulation (EC) No 1223/2009 as regards the use of a named list of substances. The date given here, 27 April 2026, is the date of the act itself; the Official Journal reference for the text we worked from is eli/reg/2026/909/oj. It touches four annexes: Annex II (prohibited), Annex III (restricted), Annex V (preservatives) and Annex VI (UV filters).

The substances named in the title are Benzyl Salicylate, Triphenyl Phosphate, Ammonium Silver Zinc Aluminium Silicate, Aluminium, water-soluble zinc salts, Acetylated Vetiver Oil, Citral, HC Blue No 18, HC Red No 18, HC Yellow No 16, Hydroxypropyl-p-phenylenediamine and its dihydrochloride salt, and DHHB.

If none of those is in your formula, this instrument is not your problem and you can stop reading here. If one of them is, the rest of this page is about which date applies to you, because there is more than one and the difference is a month of trading.

The date that is the same for everyone

From 1 January 2027, cosmetic products that do not comply with the restrictions introduced by this Regulation shall not be placed on the Union market.

That one is uniform across the entries that carry this transitional provision. The new hair-dye entries (Annex III 383 to 386) are new authorisations and carry no transitional date. "Placing on the market" is a product's first making available on the Community market (Art. 2(1)(h), Reg. (EC) 1223/2009), the Regulation's "Community" being read as the Union — so this is the date after which you cannot bring non-compliant product into EU trade at all, whether you make it in Ghent or ship it from Chennai.

The dates that are not the same for everyone

Sell-through is different. The instrument does not set one date for "not made available on the Union market". It sets four provisions, and they do not all land on the same day:

"Making available on the market" is any supply of a cosmetic product for distribution, consumption or use on the Community market in the course of a commercial activity, whether in return for payment or free of charge (Art. 2(1)(g), Reg. (EC) 1223/2009). The Regulation says "Community"; read it as the Union. It is the shelf, not the border.

This matters more than it looks. A widely-repeated version of this instrument gives a single blanket sell-through date of 1 August 2028. That date belongs to two lines only: geranial and neral, the isomers listed under entry 70. Citral itself, like the other entries with a transitional date, runs to 1 July 2028. A brand that reads the blanket figure and applies it to a citral or triphenyl-phosphate product keeps stock available for a month after it should have come off.

That is why the regulatory-watch feed exists in the form it does: one entry per instrument, dated, with the transitional provisions recorded per substance rather than compressed into a single line. A blanket date is the shape a summary takes when it is written quickly, and it is the shape that costs a brand a month at one end or the other.

The corrigenda

There are two corrigenda to Regulation (EU) 2026/909. The one dated 5 May 2026 renumbers the new Annex III entries: the text as first printed numbers them 379 to 384, the corrected text 381 to 386. The one dated 8 May 2026 corrects an Annex II reference number to 1767. If you are working from a copy printed before those dates, or from a summary written before then, those entries appear as 379 to 384 and 1752, and you are reading the uncorrected text.

Any further corrigendum, and the date it was read here, will be recorded on the regulatory watch page once the watch has read it.

The new maximum concentrations

Read from the text of the Regulation in the Official Journal on 9 October 2026, as printed in the Annex. Percentages are of the ready-for-use product.

Citral — Annex III, entry 70 (citral 5392-40-5, geranial 141-27-5, neral 106-26-3)

The labelling duty is unchanged: the presence is indicated as 'Citral' in the ingredient list above 0,001 % in leave-on and 0,01 % in rinse-off products.

The three substances sit in one entry with one limit per product type. The entry does not say in so many words whether the limit is applied to each substance or to the three together. The reading used in a given file is the assessor's, and it should be written into the file.

Benzyl salicylate — Annex III, entry 75 (118-58-1)

The labelling duty is likewise unchanged: 0,001 % leave-on, 0,01 % rinse-off.

The text we read is the Regulation as first printed. The two corrigenda above affect entry numbers and an Annex II reference, not these figures, but check the consolidated Annex before you rely on a figure in a file. The limits for the other entries in this instrument (aluminium, zinc salts, acetylated vetiver oil, the hair dyes) are not reproduced here.

Our check does not yet screen against these figures: the registry behind it loads them only once a person here has accepted them, and until then the check says so rather than returning a comfortable answer.

Which of these actually catches a natural brand

Two of them, most often.

Citral. This is the entry a botanical formulator should open first. For the worked calculation, the supplier questions and the lot-to-lot problem, see citral in essential oils. Whether citral is in your product is not a question a general rule can answer — it is a question for the certificate of analysis of each aromatic material you use, lot by lot. It is also the one entry in this instrument with two sell-through dates: 1 July 2028 for citral itself, and 1 August 2028 for its isomer lines, geranial and neral. That makes it the easiest to handle wrongly.

Benzyl Salicylate. It already had a labelling life of its own as a fragrance allergen under Annex III. This instrument moves it into a concentration question as well, which means a product that was previously only a labelling matter may now be a formulation matter. The limits are in the table above, by product type; the figure that applies to you is the one for your product type, not the highest on the list.

The three hair colourants (HC Blue No 18, HC Red No 18, HC Yellow No 16) and Hydroxypropyl-p-phenylenediamine catch salon and colour brands rather than skincare. DHHB catches sunscreen, and sunscreen is where an Annex VI question tends to be the difference between a launch and a postponement.

What to do

1. Flatten your formula to substance level. Not "essential oil blend" — the substances inside it, with a concentration range you can defend.
2. Match that list against the twelve substances above. If nothing matches, record that you checked, with the date.
3. For each match, find which of the four sell-through provisions applies. Do not use one date for all of them.
4. Separate the two questions: can you still place this (1 January 2027), and can you still sell through what you already placed (1 July or 1 August 2028).
5. Check the file, not just the pack. If a formula changes, the safety report changes (Art. 10(1), Reg. (EC) 1223/2009), the product information file changes (Art. 11(1)) and the notification changes (Art. 13(1)).
6. Date your working. When an inspector or a retailer asks why you concluded what you concluded, the date you checked against is part of the answer.

FAQ

The registry behind it

Every Annex II–VI entry as consolidated on 18 May 2026 — 2,385 entries, 36,023 substances — re-checked daily against EUR-Lex, CosIng, SCCS and IFRA. Every report is signed by David Vandevoort, pharmacist (Master, KU Leuven; PhD, KU Leuven 2010).