If your last Cosmetic Product Safety Report was signed off more than a year ago, you may already have a compliance problem. Not because your formula changed, but because the International Nomenclature of Cosmetic Ingredients system that governs ingredient naming on your label has.

Commission Implementing Decision (EU) 2025/1175 formally updates the INCI glossary. From July 30, 2026, all cosmetic products sold in the EU must follow the updated INCI glossary. This is now a legal requirement. The INCI updates add 348 new ingredients, change some existing names, and directly affect CPSR documents, product labels and Product Information Files (PIFs).

Packaging production usually takes 4 to 12 weeks, and Safety Assessors are already getting very busy. Brands that have not started checking their ingredient names, INCI compliance, and CPSR documents are already falling behind.

This guide explains what has changed, what it means for your documents, and what you need to do before July 30, 2026.

It also looks at other regulations coming at the same time, because the INCI updates are not happening alone; they are part of a bigger regulatory change in the cosmetic industry.

What Is the INCI System?

The International Nomenclature of Cosmetic Ingredients is the EU’s mandatory standardized system for naming cosmetic ingredients on product labels. It was adopted under Article 19 of Regulation (EC) No 1223/2009. Every brand placing products on the EU market must use INCI names, not trade names, not supplier codes, not generic descriptors.

What 2025/1175 changes is the reference point. The glossary that your labels, PIFs, and CPSRs are measured against has been updated. Any ingredient name on your current label that does not appear in the new glossary exactly as listed creates a labelling breach from July 30, 2026 regardless of whether the formula itself has changed at all.

How Often Does the Updated INCI Glossary Change?

The updated INCI glossary has no fixed revision schedule. The European Commission updates it when a significant volume of new ingredients has accumulated without official nomenclature, or when scientific evidence warrants reclassification of existing entries. That means updates can arrive months or several years apart; there is no predictable cycle for brands to plan around.

The 2025/1175 decision is the most substantial revision in several years. It brings the total glossary to 30,419 entries. This scale reflects how quickly the cosmetic ingredients landscape is evolving through biotechnology, green chemistry, and novel active development. 

INCI Ingredient Naming Rules: The Framework Every Brand Must Understand

The ingredient naming rules that underpin INCI compliance are more structured than many brand owners realise. They determine how a name is built, when it must change, and what documentation needs to align with it. Getting this wrong does not just create a label problem; it creates a CPSR problem.

How INCI Names Are Constructed

INCI ingredient naming follows systematic conventions that vary by ingredient origin and type.

The 2026 INCI updates include entries where a single existing name has been split into multiple distinct designations. This reflects improved characterisation of complex ingredients. A brand still using the old single name may be under-declaring components that now require separate listing. That is not just an outdated label; it is an incomplete ingredient declaration.

When Ingredient Naming Rules Require Label Changes

Three scenarios trigger a mandatory label change under the new ingredient naming rules:

• Name revision: The official INCI name has changed. The old name no longer appears as a valid entry in the 2025/1175 glossary.
• Reclassification: An ingredient has moved to a new category. The naming convention for that category is different from the one previously used.
• New mandatory entry: An ingredient previously identified by a trade name or generic descriptor now has an official INCI designation. That designation must be used on labels.

In all three cases, the action is the same. Update the label by July 30. Amend the PIF. Ask your Safety Assessor to confirm whether the CPSR remains valid or needs revision.

Ingredient Naming in Fragrances and Botanicals

Fragrances and botanical extracts carry the highest ingredient naming exposure in the 2026 updates.

For fragrances, expanded allergen rules under Regulation (EU) 2023/1545 mean individual fragrance chemicals must now be declared by their INCI name if they appear on the expanded allergen list. “Parfum” alone no longer covers them. This is a labelling change and a CPSR change simultaneously.

For botanicals, the 2025/1175 glossary introduces more granular ingredient naming that separates extraction method, plant part, and processing conditions. These distinctions were not always required before. They are now. Brands with plant-based formulations face the steepest audit workload in this area.

The 2026 Updated INCI Glossary: What Has Changed

Commission Implementing Decision (EU) 2025/1175 adds 348 new entries to the EU reference glossary for cosmetic ingredients, bringing the total to 30,419. These additions cover biotechnology-derived actives, novel emollients, functional polymers, and plant derivatives that entered widespread use without official INCI designations.

The impact varies by formulation type. 

• Products using conventional well-established ingredients
• Standard emollients
• Common preservatives
• Basic humectants are less likely to be affected 

Products using botanicals, biotech actives, or novel functional materials carry significantly higher exposure. Nomenclature in these categories has been unsettled for years. The 2025/1175 decision resolves that ambiguity through mandatory new designations.

A targeted glossary audit is the only reliable way to find out which products in your portfolio are affected. Cross-referencing every label name against the published 2025/1175 decision is not optional. It is the starting point for every other compliance action that follows.

How INCI Updates Directly Affect CPSR Validity

A CPSR is a safety assessment concluded at a specific point in time. It does not update itself when regulations change around it. The 2026 INCI updates create three distinct ways a previously valid CPSR can become problematic.

Label Misalignment and the CPSR INCI Connection

When INCI names on a label no longer match the current official glossary, the product fails Article 19. The CPSR references that ingredient list as part of its safety assessment. It now documents a formulation under names that are no longer the authorised designations.

The safety conclusions may still be correct. But the document is technically misaligned with the product’s required labelling. A Safety Assessor must resolve this before the CPSR INCI documentation can be confirmed as current and valid. 

PIF Amendments and Reassessment Triggers

The PIF must accurately represent the product as it is placed on the market. That includes correct INCI names for every cosmetic ingredient listed. Where 2025/1175 changes a declared name, the PIF must be updated. That update triggers a review obligation.

Where the name change involves a reclassification, the assessor may need to issue an amended report. An acknowledgement of the name change alone is not sufficient in those circumstances.

When New Restrictions Invalidate Safety Conclusions

A CPSR becomes unsupportable when any of the following apply:

• Concentration limits or use conditions have been revised downward since the report was issued
• An ingredient has been newly classified as a CMR substance under Regulation (EU) 2026/78
• The fragrance allergen data in the CPSR covers only the original 26 substances and not the expanded 80+
• A previously permitted ingredient now appears on Annex II or carries updated conditions under Annex III

In any of these cases, the assessor must review and, where necessary, reissue the CPSR. The existing report cannot simply be carried forward.

The 2026 INCI Compliance Landscape: What Else Is Changing

The INCI compliance obligations under 2025/1175 do not arrive alone. Three other regulatory changes land in the same window. Each has its own deadline and its own documentation impact, and all three feed the same PIF and the same CPSR that the INCI updates already require you to review.

Fragrance Allergen Expansion: Regulation (EU) 2023/1545

• Individual allergen declaration expands from 26 to over 80 substances
• Deadline: July 30, 2026, aligned with the INCI glossary update
• Full allergen profiles must be obtained from fragrance suppliers covering the complete expanded list
• Labels must be updated to include all newly mandatory individual declarations by INCI name
• The CPSR safety narrative must address the full extended allergen dataset
• Any fragrance safety certificate covering only the original 26 allergens must be replaced before July 30

CMR Substance Bans: Regulation (EU) 2026/78 (Omnibus VIII)

• New prohibitions on carcinogenic, mutagenic, and reprotoxic substances came into force May 1, 2026
• This deadline has already passed
• The bans apply to both new launches and existing stock on the market
• Any product containing a newly prohibited substance must be withdrawn immediately
• CPSRs referencing affected substances are no longer valid and require immediate reassessment

Formaldehyde Releaser Labelling

• The “releases formaldehyde” labelling threshold has been tightened to 0.001% free formaldehyde concentration.
• Products using DMDM hydantoin, imidazolidinyl urea, or diazolidinyl urea are directly in scope.
• Updated supplier documentation confirming release profiles is required and must be filed.
• CPSRs for these products must address the disclosure requirement explicitly.

None of these can be managed as a separate workstream. They share documentation dependencies. They require the same Safety Assessor review. They feed the same PIF. The only viable approach is to address all of them in parallel before July 30.

CPSR INCI Compliance: Step-by-Step Action Plan for 2026

A systematic audit framework is the only way to reach compliance by July 30. Managing this product by product without structure is how brands miss things.

Key 2026 Compliance Deadlines

The May 1 deadline has passed. If your Annex II review was not completed and your product contains a newly prohibited CMR substance, you are already in breach. The July 30 deadlines are weeks away. Packaging lead times mean the practical window for label changes is already closing.

Compliance Systems for Ongoing Updates 

Meeting July 30 is the immediate task. But the International Nomenclature of Cosmetic Ingredients system will keep evolving. New biotech ingredients, green chemistry actives, and increasingly granular botanical classifications will drive future glossary updates with the same labelling and documentation consequences as 2025/1175.

Brands that treat this as a one-time fix will face the same scramble at the next update. The brands that stay stable are those that build genuine compliance infrastructure now:

• Scheduled PIF reviews at regular intervals, not only when a change forces it
• Standing supplier data agreements that include proactive allergen and restriction updates as standard
• A Safety Assessor relationship that operates as a continuous compliance partner, not a one-time sign-off service
• An internal INCI audit process triggered automatically when new ingredients enter a formula

Proactive compliance has a predictable cost. Reactive compliance, rushed label reprints, expedited assessor reviews, retailer pressure, and possible stock withdrawal do not. The infrastructure you build now determines which of those two experiences defines every future regulatory update.

FAQs: INCI Updates 2026 and CPSR Compliance

Q1: What is the specific penalty for non-compliance with the 2026 INCI updates after July 30, 2026?

EU cosmetics regulation does not set a single fixed penalty; enforcement is handled at the member state level. In practice, non-compliant products risk market withdrawal, notification to the RAPEX rapid alert system, and formal enforcement action by national authorities. Retail partners conducting their own compliance audits can also delist products without notice. The commercial exposure from a retailer-initiated delisting can be more immediate than regulatory action.

Q2: Can I self-audit my INCI names against the 2025/1175 glossary, or do I need a qualified assessor?

The glossary cross-reference in Step 2 of the action plan can be performed in-house; it is a systematic comparison of label names against the published 2025/1175 decision. What requires a qualified Safety Assessor is the CPSR review and any PIF amendments that follow. The audit tells you what has changed. The assessor determines whether those changes affect the safety conclusions in your existing CPSR.

Q3: Do these INCI updates apply to cosmetic products that are mid-production when July 30 arrives?

Yes. The July 30, 2026 deadline applies to products placed on the market from that date. Products manufactured and labelled before July 30 with non-compliant INCI names cannot legally be placed on the EU market after the deadline. If you have stock in production with artwork already committed, escalate to your artwork and assessor teams immediately. Lead times are the critical constraint.

Q4: What should I do if my fragrance supplier cannot provide a full allergen profile for the expanded 80+ list?

This is a serious compliance gap. Without a full allergen profile, you cannot complete the fragrance section of a valid CPSR under the post-July 30 requirements. If your supplier cannot provide the data, you have two options: source an alternative fragrance supplier who can, or work with your Safety Assessor to assess whether the fragrance can be reformulated. Do not label the fragrance as compliant based on partial data; that creates a greater liability than the labelling gap itself.

Q5: Does the 2025/1175 INCI update affect borderline cosmetic and medical device products?

Products classified as medical devices are regulated under the EU Medical Device Regulation, not the EU Cosmetics Regulation, and are not subject to the Article 19 INCI labelling requirement in the same way. However, borderline products, those that could be classified as either a cosmetic or a medical device depending on their claims, should review their regulatory classification before assuming INCI requirements do not apply. Misclassification carries its own separate risk.

Q6: If the formula has not changed, do I still need a new CPSR after the INCI glossary update?

Not automatically, but you cannot assume the existing CPSR remains valid without checking. Your Safety Assessor must confirm that the INCI name changes are administrative only and do not reflect reclassifications that bring new restriction data. They must also confirm that no other element of the 2026 regulatory package, CMR bans, allergen expansion, or formaldehyde thresholds, affect the safety conclusions in the existing report. A brief written confirmation from your assessor is the minimum required documentation.

Q7: Are these 2026 INCI compliance obligations relevant for UK brands?

UK brands placing products on the EU market must comply with EU INCI rules, including the 2025/1175 update. The UK’s own post-Brexit cosmetics framework is developing on a separate trajectory. Brands operating in both markets must track ingredient naming compliance requirements independently for each regulatory zone. An INCI name that is valid in the UK framework may not align with the updated EU glossary, and vice versa.