ECHA Tightens Limits on 3 Preservatives in Cosmetics & Packaging

On 2 May 2026, the European Chemicals Agency (ECHA) updated Annex V of the EU Cosmetics Regulation, imposing stricter migration limits (≤0.5 mg/kg) for phenoxyethanol, caprylyl glycol, and potassium sorbate in all aqueous cosmetic and packaging products. This revision directly affects manufacturers and suppliers of plant-based cosmetic packaging exporting to the EU — particularly those relying on legacy EN 13624 test reports.

Event Overview

On 2 May 2026, ECHA published an update to Annex V of Regulation (EC) No 1223/2009, adding revised migration limits for phenoxyethanol, caprylyl glycol, and potassium sorbate. The new limit applies uniformly to all water-containing cosmetic formulations and associated packaging materials. Chinese packaging suppliers previously certified under the older version of EN 13624 must complete new migration testing and issue updated Declarations of Conformity (DoC) by 30 June 2026.

Industries Affected by the Revision

Plant-based packaging manufacturers: These suppliers face direct compliance pressure, as the new limit targets migration from packaging into aqueous cosmetic products. Those using bio-sourced polymers (e.g., PLA, cellulose derivatives) may exhibit different migration profiles than conventional plastics — making prior EN 13624 data insufficient.

Export-oriented cosmetic contract packagers: Firms assembling or filling cosmetics into third-party plant-based containers must now verify that both the formulation and its packaging jointly meet the ≤0.5 mg/kg threshold. Responsibility for DoC updates may fall jointly on packager and container supplier.

EU importers and brand owners sourcing from China: Importers remain legally responsible for product compliance under EU law. They must obtain updated DoC and test reports from suppliers before placing products on the EU market after 30 June 2026 — otherwise risk non-compliance penalties or customs rejection.

Key Points for Enterprises and Practitioners to Monitor and Act On

Confirm applicability to your specific product category

Verify whether your product falls under ‘aqueous cosmetic formulations’ as defined in Annex V — including toners, serums, emulsions, and gels. Anhydrous products (e.g., balms, oils) are not subject to this revision. Misclassification may lead to unnecessary retesting.

Review existing EN 13624 test reports for scope alignment

Legacy EN 13624 reports often used different simulants, time/temperature conditions, or detection limits. Compare original test parameters against the updated requirements in ECHA’s 2026 guidance. If parameters differ, retesting is mandatory — even if prior results were below 0.5 mg/kg.

Update Declarations of Conformity with traceable test evidence

DoC statements must reference the new test report number, laboratory accreditation (e.g., ISO/IEC 17025), and exact migration values per substance. Generic or retrospective DoC updates without supporting data will not satisfy EU market surveillance authorities.

Coordinate timelines with EU importers ahead of 30 June deadline

Testing turnaround times for migration studies typically require 4–6 weeks. Suppliers should initiate requests with accredited labs by mid-May 2026 at the latest, and share draft reports with EU partners for pre-approval review to avoid last-minute delays.

Editorial Perspective / Industry Observation

Observably, this revision signals a tightening of regulatory scrutiny on indirect additives — especially where bio-based materials intersect with preservative chemistry. Analysis shows ECHA is treating packaging not as inert infrastructure, but as an active component influencing final product composition. This shift reflects broader EU policy trends toward cumulative exposure assessment and lifecycle-aware chemical regulation. From an industry perspective, it is more accurately understood as an enforcement trigger than a new policy introduction: the substances were already restricted, but the migration threshold has now been harmonized and lowered to a single, enforceable value across all aqueous systems. Continued attention is warranted as national market surveillance authorities begin verifying DoC submissions post-June 2026.

This update carries practical implications for supply chain coordination, technical documentation rigor, and timing discipline — rather than introducing entirely new compliance categories. It underscores that regulatory alignment for plant-based packaging extends beyond biodegradability or feedstock origin, and now includes precise migration control under real-use conditions.

Information Sources:
European Chemicals Agency (ECHA) – Annex V update notice, published 2 May 2026;
Regulation (EC) No 1223/2009 on cosmetic products;
EN 13624:2015 (Cosmetic packaging — Determination of migration of substances from packaging into cosmetic products).
Note: Ongoing verification of national transposition and enforcement guidance is recommended beyond the initial ECHA notice.