Law firm Mishcon de Reya LLP has published guidance on the updates to UK and EU cosmetics regulations that beauty businesses need to prepare for in 2026, signalling that the divergence between the two regimes is set to deliver another round of compliance work for brands selling on both sides of the Channel.

The starting point for any responsible person is straightforward: the UK and EU cosmetics frameworks, which began as a single body of law under Regulation (EC) No 1223/2009, no longer move in lockstep. Since the end of the Brexit transition period, the UK has operated its own cosmetic products regime under the Cosmetics Regulation as retained and amended in domestic law, with the Office for Product Safety and Standards (OPSS) as the competent authority and the Scientific Advisory Group on Cosmetic Safety (SAG-CS) replacing the EU's Scientific Committee on Consumer Safety (SCCS) as the UK risk assessment body. The EU, meanwhile, continues to amend Annexes II through VI of Regulation 1223/2009 through Commission implementing measures, and it is advancing its broader review of the cosmetics framework as part of the chemicals strategy agenda.

That dual-track structure is precisely why a 2026-focused advisory from a firm of Mishcon de Reya's standing matters to formulators and regulatory leads. Any change to a restricted substance list, a new maximum concentration limit, or a revised labelling requirement in one jurisdiction but not the other forces a product-by-product decision: reformulate, run a dual SKU strategy, or withdraw from one market.

For teams building 2026 compliance calendars, the categories of change that typically arrive from both regulators include the following. First, restriction and prohibition updates: entries added to the banned or restricted annexes following risk opinions from the SCCS in the EU or SAG-CS in the UK. Second, new labelling and notification obligations, processed through the EU's CPNP portal and the UK's Submit Cosmetic Product Notifications (SCPN) system respectively. Third, the ongoing dialogue in the EU around elements such as fragrance allergen labelling and the digital labelling possibilities raised in the cosmetics regulation review.

The commercial stakes are not trivial. Beauty businesses operating dual UK-EU portfolios must maintain two product information files, two responsible-person arrangements — with the UK requiring a UK-established responsible person — and two notification pipelines. Where a 2026 amendment tightens an ingredient restriction in the EU only, UK stock may remain saleable while EU inventory becomes non-compliant on the applicable date, and vice versa. Procurement teams will want advance visibility of any annex changes so raw material contracts and minimum order quantities can be adjusted before deadlines bite, rather than after.

Contract manufacturers and private-label brands carry an additional layer of exposure. Under both regimes, the responsible person bears the compliance burden, but brands relying on third-party manufacturers frequently discover annex-driven non-compliance only at the audit or notification stage. A 2026 legal update is therefore not just a legal-department document; it belongs on the desk of heads of formulation, QA and supply chain.

What should readers watch next? The concrete data points that will define the practical impact of the 2026 updates are the specific Commission implementing regulations and UK statutory instruments as they are published, along with the timing of any SAG-CS and SCCS opinions that feed them. Mishcon de Reya's full guidance sets out the detail of the changes it identifies, and professionals with dual-market portfolios should review it against their current ingredient decks and notification records before the new obligations take effect.