What hair care brands should review now, from dye concentrations to fragrance specifications and stock deadlines.
Published by BODA, a hair care manufacturer. Last updated: October 30, 2026. This is general information, not legal advice; confirm details with your Responsible Person or safety assessor. It covers EU rules only, and we plan to review it before January 1, 2027.
The four hair-dye restrictions in Commission Regulation (EU) 2026/909 have applied since May 18, 2026. Article 2 sets entry into force at 20 days after publication. Market-transition dates sit in separate annex footnotes, and none of the four dye entries has one. Color brands should already be checking these conditions, not leaving the work until January 2027.
Shampoos, conditioners and styling products run on a different timetable. For these, the first job is usually supplier data, since finished-product concentrations can only be calculated from current specifications. Start with products whose raw-material records are incomplete or no longer match the production formula.
What are the four dye limits?
For oxidative products, the percentage is the concentration applied to hair after mixing under oxidative conditions. For non-oxidative products, it is the concentration in the ready-for-use preparation.
| Hair dye | Oxidative | Non-oxidative |
|---|---|---|
| HC Blue No. 18 | 0.35% | 0.35% |
| Hydroxypropyl-p-phenylenediamine and its dihydrochloride salt | 2% | Entry specifies oxidative use only |
| HC Yellow No. 16 | 1% | 1.5% |
| HC Red No. 18 | 1.5% | 0.5% |
The English annex (pages 14–17) lists the oxidative limits in the “Other” column and the non-oxidative limits in the maximum-concentration column, so reading only one column misses half the requirement. The May 5 corrigendum renumbered these entries as 383–386. Oxidative labels must also carry the mixing ratio and the prescribed allergy warnings, so the formula calculation and the artwork should be reviewed together.
Why fragrance data is the bottleneck
Benzyl Salicylate has a 0.5% ceiling in rinse-off skin and hair products (excluding shower gel/bath products); non-spray, non-aerosol leave-on skin and hair products (excluding body lotion); and leave-on hair sprays and aerosols. Its ingredient-list disclosure thresholds are much lower: above 0.001% for leave-on products and above 0.01% for rinse-off products. The two are separate checks, so a formula that stays under the use limit may still have to list the substance.
A label that only says “Parfum” gives you nothing to calculate with. Ask early for the composition data, include contributions from other raw materials, and note which formula version the data covers.
Illustrative example (invented figures): a leave-in hair mask contains 0.8% fragrance, and the current specification lists Benzyl Salicylate at 5% of that fragrance. So 0.8% × 5% = 0.04% in the finished product. That is well below the 0.5% limit but above the 0.001% leave-on disclosure threshold, so the substance still goes on the ingredient list. Rerun the calculation whenever the fragrance batch changes.
Which other ingredients are affected?
This article covers the provisions most relevant to hair care, not every substance in the regulation; the full list is in the official text.
| Substance | Change |
|---|---|
| Citral | 1.2% limit for leave-on hair products and rinse-off skin and hair products (page 9) |
| Aluminium-containing ingredients | Separate hair categories, including one for potential lung exposure by inhalation |
| Acetylated vetiver oil | Category-specific limits and a raw-material stabilization condition |
| Water-soluble zinc salts | Revised in Annex III |
| DHHB | DnHexP impurity limited under Annex VI |
| Triphenyl Phosphate | Added to Annex II's prohibited list; an existing cosmetic plasticizer; its own transition provision is on page 7 |
For products that do not meet the new requirements, zinc salts, DHHB and Triphenyl Phosphate share a January 1, 2027 placement deadline and a July 1, 2028 final availability deadline.
Which deadlines apply to stock?
For affected products that do not meet the new requirements, the main transition dates are:
| Date | Consequence |
|---|---|
| January 1, 2027 | No further placement on the EU market under the relevant transition provisions. |
| July 1, 2028 | No further availability under the general transition provisions, including those for Citral itself. |
| August 1, 2028 | The separate final availability date for Geranial and Neral under their specific footnote. |
An August deadline for Geranial or Neral does not extend the deadlines for other ingredients in the same product.
Article 2 of the Cosmetics Regulation separates first placement from later availability. Keep records of the actual products and their supply history, because an established SKU does not automatically give later batches the transition status of stock already on the market.
What we have seen in BODA projects
Three situations from this year's projects show where the review tends to stall. Details are anonymized.
Dye limits assumed to have a transition period. In May 2026, shortly after the regulation took effect, a customer developing an oxidative salon hair color under OEM terms assumed a grace period and had already started trial production. Once the team confirmed that the four dye entries applied immediately, trials were paused. The concentration after mixing was recalculated, dye loadings were adjusted, the safety report (CPSR) was updated, and sampling restarted.
An archived fragrance specification. In the second quarter, a customer preparing a fragranced hair mask for the EU calculated compliance from a fragrance specification archived two years earlier. Checking against the supplier's current batch information showed the composition had changed. The team obtained the specification for the batch in use, recalculated the allergen concentrations in the finished product and corrected the safety file.
Composition data held back by an NDA. Also in the second quarter, a customer launching a multi-fragrance shampoo line asked for the full fragrance breakdown only when the packaging artwork was nearly final. The fragrance supplier required an NDA first, and the back-and-forth took time. Starting the NDA at the beginning of the project gets the composition data in hand before artwork review.
In each case the fix was the same: get current supplier data and calculate against the formula version in production before packaging is locked.
What to ask your suppliers
Send these requests together, and keep the answers in one record per product:
- the formula version each specification refers to;
- fragrance composition data detailed enough to calculate finished-product concentrations;
- the contribution of other raw materials to any restricted substance;
- the product category: oxidative or non-oxidative, rinse-off or leave-on, spray or non-spray;
- batch and supply records showing which stock was placed on the market, and when.
Then give each unresolved product an owner before the next production run is approved or replacement packaging is ordered:
| Team | Task |
|---|---|
| Formulation | Concentration calculation for each restricted substance |
| Procurement | Missing raw-material and fragrance specifications |
| Regulatory | Label review and safety-documentation review |
| Supply chain | Batch records and stock status |
Frequently asked questions
Are the hair dye restrictions already in force?
Yes. The four dye entries have applied since May 18, 2026, and none carries a market-transition footnote, so there is no reason to wait for January 2027.
Does a product below the Benzyl Salicylate limit still need to list it?
It may. The use limit and the disclosure thresholds are separate checks, and disclosure applies above 0.001% for leave-on products and above 0.01% for rinse-off products.
Does the August 2028 deadline extend the deadline for the whole product?
No. It applies to Geranial and Neral under their specific footnote. Other ingredients in the same product keep their own dates.
Planning a hair care project for the EU?
If you are sourcing hair care products and want the brief reviewed before quotation, send BODA your product type, target market, formula direction, packaging reference, quantity per SKU and launch date through our OEM and private label process. Not ready with a complete brief? Send one sentence with the product, destination market and estimated quantity through the BODA contact page.
Still building a supplier list? See our private label shampoo manufacturer list for a side-by-side comparison.
