Aluminium in cosmetics have been used in antiperspirants, sunscreens, toothpastes, lip products, and colour cosmetics for decades. However, following updated safety assessments from the Scientific Committee on Consumer Safety (SCCS), the European Commission has introduced new concentration limits through Commission Regulation (EU) 2026/909.
While many discussions refer to an aluminium deodorant EU ban 2026, the regulation does not ban aluminum; it introduces enforceable limits that will require reformulation for a significant number of products.
The new aluminium sunscreen limits EU rules, updated aluminium salts deodorant CPSR requirements, and broader EU 2026 aluminium cosmetics obligations mean brands must act now.
Under Regulation 2026/909 aluminium provisions, non-compliant products cannot be placed on the EU market after January 1, 2027.
This guide explains the new aluminium cosmetics EU 2026 rules, concentration limits, SCCS findings, CPSR requirements, reformulation challenges, and the practical steps brands should take to remain compliant.
What Changed Under Regulation (EU) 2026/909 Aluminium Rules?
Regulation (EU) 2026/909 amends Annex III of the EU Cosmetics Regulation (EC) No 1223/2009. Annex III lists substances permitted in cosmetics subject to specific conditions, including maximum concentrations, product types, and mandatory warnings. Previously, aluminium ingredients were governed by general safety principles rather than specific numerical limits. That has now changed, with category-specific limits assigned to each product type based on SCCS exposure modelling.
| Detail | Information |
| Regulation | Commission Regulation (EU) 2026/909 |
| Amends | Annex III of EC No 1223/2009 |
| Type of restriction | Maximum permitted concentration limits |
| Market placement deadline | January 1, 2027 |
| Sell-through deadline | July 1, 2028 |
| Trigger | SCCS cumulative exposure findings |
Product categories affected:
- Deodorants and antiperspirants (all formats)
- Toothpastes and mouthwashes
- Sunscreens and UV products
- Lip products
- Colour cosmetics and makeup
- Leave-on hair and skin products
Any product on the EU market containing an Annex III aluminium compound must be reviewed against the new conditions. If the current formulation exceeds the new limits, it is no longer compliant, regardless of when it was developed or assessed.
Who is most affected:
- Brand owners managing reformulation timelines and updated safety assessments
- Responsible Persons legally accountable for CPSR and PIF compliance
- Contract manufacturers confirming ingredient concentrations for clients
- Importers taking on RP obligations for non-EU products
Why Is the EU Restricting Aluminium in Cosmetics?
The EU introduced new aluminium restrictions following assessments by the Scientific Committee on Consumer Safety (SCCS), which evaluated cumulative exposure from daily consumer use of multiple aluminium-containing cosmetic products.
The SCCS found that consumers may be exposed to aluminium from several sources in a single day, including antiperspirants, toothpastes, lip products, sunscreens, and makeup. While individual products may be safe on their own, aggregate exposure from repeated daily use can significantly increase total aluminium intake.
A key part of the SCCS assessment was the Margin of Safety (MoS) calculation:
For cosmetic ingredients, an MoS of 100 or greater is generally considered acceptable. The SCCS concluded that certain product categories, particularly antiperspirants, oral-care products, lip products, and spray cosmetics, could contribute to cumulative exposure levels that reduce the Margin of Safety below preferred thresholds.
As a result, Commission Regulation (EU) 2026/909 introduced product-specific concentration limits to ensure aluminium-containing cosmetics remain safe under realistic consumer use conditions. The goal is not to ban aluminium, but to maintain an adequate Margin of Safety while accounting for aggregate exposure across daily cosmetic routines.
Which Aluminium Ingredients Are Covered by the EU 2026 Aluminium Cosmetics Rules?
Aluminium Chlorohydrate
The primary antiperspirant active in most roll-ons, sticks, sprays, and aerosols. It temporarily blocks sweat ducts and has relatively high dermal absorption potential, especially on damaged or shaved skin, making it the most closely scrutinised ingredient under the new rules.
Aluminium Zirconium Compounds
Used in clinical-strength and long-lasting antiperspirant formulations. Often combined with glycine to improve skin feel and stability. Subject to specific concentration caps that differ from aluminium chlorohydrate limits.
Aluminium Hydroxide
Functions as a buffering agent, opacifier, and surface coating. Commonly found in sunscreens as a coating on UV filter particles, foundations, and some hair products. Often present for functional rather than active purposes, but concentration limits still apply.
Aluminium Starch Octenylsuccinate
A modified starch used for absorbency and texture. Common in dry shampoos, setting powders, and loose colour cosmetics. Brands using this in high-coverage or daily-use products should check finished product concentrations carefully.
Other Aluminium Salts Listed in Annex III
Several additional aluminium compounds appear across nail products, oral care, and pigment formulations. Brands should review all aluminium-containing INCI names, not just the most common ones.
New Aluminium Concentration Limits Under Regulation (EU) 2026/909
| Product Category | Maximum Permitted Aluminium Level |
| Spray antiperspirants | 6.25% (as aluminium) |
| Non-spray antiperspirants | 10.60% (as aluminium) |
| Toothpaste | 0.65% (as aluminium) |
| Lip products | 2.65% (as aluminium) |
| Sunscreens (face) | 1.40% (as aluminium) |
| Sunscreens (body) | 0.77% (as aluminium) |
| Non-spray makeup (face/body) | 1.54% (as aluminium) |
| Eye makeup | 2.53% (as aluminium) |
Figures are expressed as aluminium content. Verify exact limits against the official regulation text and confirm interpretation with a qualified safety assessor.
Aluminium Deodorant EU Ban 2026: What the New Antiperspirant Rules Actually Mean
There is no outright aluminium deodorant EU ban. What exists is a set of concentration limits that will require many current antiperspirant formulations to be adjusted.
Spray Antiperspirants
Spray formats face a limit of 6.25% aluminium. Broader skin-surface coverage and potential inhalation drive the lower limit compared with non-spray formats.
Aerosol Antiperspirants
Aerosols carry the greatest combined exposure risk, dermal, inhalation, and accidental ingestion. They are subject to the most restrictive concentration assumptions in SCCS modelling.
Roll-On Antiperspirants
Non-spray formats are permitted up to 10.60% aluminium. Many roll-on formulations may already fall within this limit, but confirmation is still required.
Stick Deodorants
Stick formats follow the non-spray limits. Brands should verify the calculated aluminium metal equivalent in the finished product, not just the active ingredient percentage.
| Format | Exposure Risk | Reformulation Likelihood |
| Aerosol antiperspirant | High | High |
| Spray antiperspirant | High | High |
| Roll-on antiperspirant | Medium–High | Medium–High |
| Stick deodorant | Medium | Medium |
Aluminium Salts Deodorant CPSR Requirements Under the New Regulation
Updating CPSRs for aluminium salts deodorant compliance is one of the most time-sensitive tasks brands face. CPSRs cannot simply be annotated, they must be substantively revised.
New Exposure Calculations
Safety assessors must use the product-specific maximum permitted concentrations as the basis for systemic exposure modelling. Previous CPSRs may have used higher aluminium concentrations or different exposure assumptions.
Aggregate Exposure Assessments
A compliant CPSR must now acknowledge that consumers use multiple aluminium-containing products simultaneously. Assessors should reference the SCCS aggregate exposure methodology and document how cumulative risk has been considered.
Updated Toxicological References
The CPSR must reference the most current SCCS opinion on aluminium. Older opinions, even those used in relatively recent CPSRs, may not reflect the current regulatory position.
CPSR Documentation Requirements
Updated CPSRs must clearly demonstrate:
- The aluminium compound identity and concentration in the finished product
- Compliance with the Annex III limit for the relevant product category
- Exposure calculations using current methodology
- Aggregate exposure consideration
When Existing CPSRs Must Be Updated
A CPSR must be updated if:
- The product contains an aluminium compound listed in the amended Annex III
- The current CPSR does not reference Regulation (EU) 2026/909
- The formulation concentration exceeds the new limits and reformulation is required
- The safety assessor used an outdated SCCS opinion as the toxicological reference
Aluminium Restrictions for Toothpastes and Oral Care Products
Toothpaste Limits
Toothpaste is permitted up to 0.65% aluminium, one of the lowest limits in the regulation. This reflects the direct oral exposure route and the fact that a portion of toothpaste is swallowed during normal use.
Mouthwash Restrictions
Aluminium concentrations in mouthwash are typically lower than in toothpaste, but brands should verify finished product levels against the applicable limit.
Oral Exposure Risks and Children
Oral ingestion results in more direct systemic aluminium uptake than dermal absorption. Children swallow more toothpaste as a proportion of body weight than adults, a factor the SCCS specifically noted in its exposure modelling. Brands marketing toothpaste to children should pay particular attention to aluminium concentrations and labelling.
Aluminium Sunscreen Limits EU:
Why Sunscreens Received Special Attention
Sunscreens are applied to large body surface areas and left on the skin for extended periods, sometimes reapplied multiple times per day. This significantly increases systemic aluminium absorption compared to rinse-off or smaller-area products.
Aluminium-Coated UV Filters and Leave-On Exposure
Titanium dioxide and zinc oxide UV filters are commonly coated with aluminium compounds to improve dispersibility and reduce photoreactivity. These coatings contribute directly to the total aluminium content of the finished product. Leave-on application across the entire body creates a high cumulative dermal exposure, which is why body sunscreens face a tighter limit (0.77%) than face sunscreens (1.40%).
Formulation and SPF Testing Implications
Brands may need to source UV filters with alternative coatings or reduce aluminium-based thickeners. Any change to a UV filter coating or formulation matrix may affect SPF performance, reformulated sunscreens may require repeat SPF and UVA protection testing before being placed on the market.
How the New Rules Affect Makeup and Colour Cosmetics
Lipsticks and Lip Balms
Lip products carry a combined dermal and oral exposure risk, consumers ingest measurable quantities through daily use. The 2.65% aluminium limit reflects this dual exposure pathway.
Foundations and Face Products
Non-spray face and body makeup is subject to a 1.54% aluminium limit. Aluminium compounds appear in some foundations and concealers as texture agents, slip modifiers, or pigment carriers.
Eye Makeup
Eye makeup carries a slightly higher permitted limit of 2.53% aluminium, reflecting different exposure assumptions for periorbital application. However, periorbital skin is thinner and more permeable, brands should factor this into safety assessments.
Nail Products
Nail products carry lower systemic risk due to the nail plate barrier. Concentration limits still apply, but the likelihood of reformulation is low.
Which Products Are Most Likely to Require Reformulation?
| Product Category | Exposure Risk | Reformulation Likelihood |
| Aerosol antiperspirants | High | High |
| Spray antiperspirants | High | High |
| Roll-on antiperspirants | Medium–High | Medium–High |
| Toothpaste | Medium | Medium |
| Lip products | Medium–High | Medium |
| Sunscreens (body) | Medium | Medium |
| Sunscreens (face) | Medium | Medium |
| Foundations | Low–Medium | Low |
| Eye makeup | Low–Medium | Low |
| Nail products | Low | Low |
Compliance Deadlines for EU 2026 Aluminium Cosmetics
January 1, 2027- Market Placement Deadline
From this date, no non-compliant products may be placed on the EU market, including stock supplied to distributors, retailers, online platforms, or sold directly to EU consumers.
July 1, 2028- Sell-Through Deadline
Products legitimately placed on the market before January 1, 2027 may remain on sale until July 1, 2028. After this date, all non-compliant products must be withdrawn from EU sales channels.
Transition Planning Timeline
| Milestone | Recommended Timing |
| Portfolio audit complete | Now |
| Reformulation brief issued | Q3–Q4 2025 |
| Reformulation and stability testing | Q4 2025–Q2 2026 |
| Updated CPSR commissioned | Q1–Q2 2026 |
| PIF updated and filed | Q2–Q3 2026 |
| Compliant product placed on the market | Before January 1, 2027 |
What Cosmetic Brands Need to Do Now
Audit Aluminium-Containing Ingredients
Review every product in your portfolio for aluminium-containing INCI names. Check raw material specifications and finished product data sheets, not just high-level ingredient summaries.
Verify Finished Product Concentrations
Calculate the aluminium metal equivalent for each compound in each product. Compare against the category-specific limits in Regulation (EU) 2026/909.
Update CPSRs
Commission updated safety assessments for all products containing aluminium compounds. Ensure assessors explicitly reference the current SCCS opinion and Regulation (EU) 2026/909.
Assess Reformulation Requirements
Where concentrations exceed the new limits, begin reformulation immediately. Allow time for ingredient substitution, stability and compatibility testing, efficacy testing, and re-assessment by your safety assessor.
Review Supplier Documentation and Update PIFs
Confirm that raw material suppliers can provide specifications for aluminium compound identity, purity, and concentration. Update PIFs to reflect the current formulation, updated CPSR, and any labelling changes. Incomplete PIFs create enforcement risk during market surveillance.
What Happens If Products Fail to Comply?
If a product does not comply with the new aluminium limits, it could be removed from sale, recalled, or dropped by retailers and distributors. From 2027 onwards, EU authorities will actively enforce these rules, and non-compliance could harm both sales and brand reputation.
Common Compliance Mistakes to Avoid
- Assuming existing products are compliant, many were formulated before these limits existed
- Ignoring aggregate exposure, single-product CPSR analysis is no longer sufficient
- Using outdated SCCS opinions, older references may not reflect current toxicological thresholds
- Delaying reformulation, antiperspirant and sunscreen reformulation takes months; time is short
- Failing to update PIFs, a compliant formulation with an outdated PIF still carries enforcement risk
Preparing for the EU’s New Aluminium Cosmetic Restrictions
Regulation (EU) 2026/909 replaces general safety principles with specific, enforceable aluminium limits, and those limits apply to products already on the market. Antiperspirants, toothpastes, sunscreens, and lip products face the greatest reformulation burden.
FAQs
Why is aluminium used in cosmetics?
Aluminium compounds are used in cosmetics to reduce sweating, absorb excess oil, improve texture, enhance product stability, and coat UV filters used in sunscreen formulations.
Is aluminium chlorohydrate safe in antiperspirants?
Aluminium chlorohydrate is considered safe in antiperspirants when used within the concentration limits established by Regulation (EU) 2026/909 and supported by SCCS safety assessments.
Is aluminium chlorohydrate banned in Europe?
Aluminium chlorohydrate is not banned in the European Union. It remains permitted in cosmetic products, including antiperspirants, provided the applicable Annex III concentration limits are met.
Is aluminium banned in EU cosmetics?
Regulation (EU) 2026/909 sets concentration limits; it does not ban aluminum. Compliant products may continue to use aluminium compounds within the permitted levels.
Which aluminium salts are affected by Regulation (EU) 2026/909?
The regulation covers aluminium chlorohydrate, aluminium zirconium compounds, aluminium hydroxide, aluminium starch octenylsuccinate, and other aluminium salts listed in the amended Annex III.
What are the new aluminium concentration limits?
Limits vary by product category, from 0.65% for toothpaste to 10.60% for non-spray antiperspirants. Check the official regulation text and confirm limits with your safety assessor.
Does Regulation (EU) 2026/909 apply to imported cosmetics?
All cosmetics placed on the EU market, whether manufactured in the EU or imported, must comply. The Responsible Person for imported products holds the same compliance obligations.
Do brands need a new CPSR?
In most cases, yes. Any CPSR for a product containing aluminium compounds should be reviewed and updated to reference Regulation (EU) 2026/909 and the current SCCS opinion.
Are natural aluminium minerals affected?
The regulation applies to aluminium compounds by function and concentration, not by whether they are synthetic or naturally derived. Naturally occurring aluminium compounds used in cosmetics fall within the scope of they are listed in Annex III.
Are sunscreens affected by the new aluminium restrictions?
Yes, sunscreens are subject to aluminium concentration limits under the new rules, particularly for full-body application products.
Can existing stock still be sold after January 2027?
Yes, until July 1, 2028. Products placed on the market before January 1, 2027 may remain on sale during the sell-through period. After July 1, 2028, non-compliant products must be withdrawn.
How do I update a CPSR for aluminium compliance?
Work with a qualified cosmetic safety assessor. They will need the updated formulation data, finished product aluminium concentrations, and should reference Regulation (EU) 2026/909 and the current SCCS aluminium opinion in their assessment.
