Regulatory signals from ECHA rarely target niche substances – they usually affect ingredients we rely on in everyday safety assessment and R&D work.This time is no different: salicylic acid returns in the context of aggregate exposure (including its esters), the CMR intention for 7-hydroxycitronellal has been put on hold, and maleic acid and climbazole enter the stage with harmonised classification intentions.From the outside, this may look like another “regulatory update package”, but in practice it means very concrete decisions for formulators, brands and safety assessors – from UV filters and fragrance compositions to technical ingredients.
Salicylic acid back under SCCS review – this time, the sum matters
Salicylic acid is once again under SCCS evaluation. The European Commission has requested an assessment of aggregate exposure, considering not only salicylic acid itself but also salicylate esters, which may metabolise into salicylic acid after cosmetic application. Aggregate exposure represents a continuation of the regulatory approach – moving from single-substance assessment to cumulative exposure evaluation. In practice, this new SCCS mandate may have the strongest impact on UV filter-containing products and formulations where salicylates are also present in fragrance compositions.
7-Hydroxycitronellal (CAS 107-75-5) – intention withdrawn
The fragrance industry can breathe a sigh of relief. The proposed harmonised classification Repr. 2, H361d for hydroxycitronellal has been put on hold, and the intention withdrawn. Had a CMR classification been adopted, the consequences for cosmetics would have been significant, given how widely this ingredient is used. However, the question remains: with such concerns raised, is it still worth using in formulations?
What does this mean for formulators and R&D?
Hydroxycitronellal remains permitted (under Regulation 1223/2009). It is listed as an allergen (Annex III, entry 72):
- must be declared in the ingredient list when exceeding:
– 0.001% in leave-on products
– 0.01% in rinse-off products
Maximum concentration in finished product: 1% (except for oral use products).
- It is prohibited in toys (EU 2020/2089), with an exception for cosmetic kits for children.
Maleic acid (CAS 110-16-7) – harmonised classification intention submitted
Maleic acid has been submitted by Austria for harmonised classification and labelling (CLH) in ECHA.
The scope of the intention includes updates in health hazard classifications, particularly: Acute Tox. 4 (H302), Skin Corr. 1 (H314), Eye Dam. 1 (H318)
This may become relevant in the context of occupational safety and handling of the substance.
Benzyl Benzoate (CAS 120-51-4) – CLH intention. What does it mean?
Benzyl benzoate has been included in the CLH process. This is currently a data evaluation stage – no decision or legal change has been made yet.
The intention concerns classification as Skin Sens. 1B (H317). If harmonised classification is adopted in the future, it may impact:
- classification of mixtures
- SDS and raw material documentation
- “hypoallergenic” product strategies
- marketing communication
Sodium Fluoride (CAS 7681-49-4) – public consultation closed
The ECHA public consultation on sodium fluoride classification as Repr. 1B and ED HH 1 closed on 16 January 2026.
One thing is clear from submitted comments: the oral care sector, dental professionals, and parts of the public health community strongly support fluoride.
The debate focused on quality of scientific evidence and proportionality of regulatory consequences.
A potential CMR classification would trigger Article 15 of Regulation 1223/2009, posing a real risk of a ban in toothpastes and mouthwashes.
Now, the key will be RAC’s opinion. For the cosmetics sector, this is one of the most important regulatory discussions in oral care in years.
Will pine resins be classified as CMR? The regulatory thriller continues
The CLH process for rosin and its derivatives (CAS: 97489-11-7) is currently ongoing at ECHA, with a proposal on the table for classification as Repr. 2, H361d, indicating suspected reproductive toxicity. Some Member States are leaning towards a developmental toxicity classification, while the industry is strongly opposing this direction.
According to industry organisations such as HARRPA, H4R and PCA, there is no scientific basis for a CMR classification, and the developmental effects observed in studies are considered secondary rather than a result of direct toxicity. The industry also emphasises that these are natural and renewable substances widely used in everyday products, from adhesives to chewing gum, and that for many applications there are no viable alternatives. Public consultations have already been completed and the decision now rests with RAC, which will have to determine whether these effects are secondary or represent a real hazard.
Ethanol
Ethanol has experienced a true regulatory rollercoaster in recent years. Initial concerns around a possible CMR classification raised the question of whether a key ingredient in disinfectants could be significantly restricted or even pushed out of the biocidal market.
However, on 23 February 2026, the Biocidal Products Committee at the European Chemicals Agency concluded that safe use in product types PT 1, 2 and 4 has been demonstrated, allowing ethanol to move forward within the Biocidal Products Regulation framework.
The question of CMR classification has not disappeared but remains unresolved at this stage. Gaps in dermal and inhalation exposure data, combined with the fact that most robust evidence relates to oral consumption rather than topical application such as hand disinfection, have shifted the discussion into the scope of the CLP Regulation.
As a result, ethanol is still very much in play, and the disinfection sector can, at least for now, breathe a temporary sigh of relief.
