EU CMR omnibus 2025/877: Annex II alignment applied from 1 September 2025
Original source
Regulation / actCommission Regulation (EU) 2025/877 of 12 May 2025 amending Regulation (EC) No 1223/2009 as regards the use in cosmetic products of certain substances classified as carcinogenic, mutagenic or toxic for reproduction
Regulatory Details
Official source. Regulation (EU) 2025/877
Key points
- Amends 1223/2009 for substances classified CMR under CLP.
- Applies 1 September 2025.
- Unless an exemption is listed, the substances go to Annex II (prohibited).
- Check the annex table for the exact chemical identifiers — common names in trade decks are not the law.
Dates. Adopted 12 May 2025; applies 1 September 2025.
Verify in the official text. Full list of Annex II additions and any derogations.
Open questions. Confirm any transitional stock rules and whether your exact INCI / product type is named. This desk brief is a prioritisation aid, not a legal determination.
What changed: Another CMR wave entered Annex II from 1 September 2025.
Who is affected: All EU cosmetics; extra attention for nail, color, and solvent-heavy systems.
Suggested next steps: Diff your INCI deck against the 2025/877 annex. Quarantine any hit.
Business Impact
On 12 May 2025 the Commission adopted Regulation (EU) 2025/877, applying from 1 September 2025, to stop use of further CMR-classified substances in cosmetics unless a specific exemption is granted.
If you have not screened the new Annex II names against every EU SKU, you are late — this date is already in the past of this desk year.
Risk is high for color cosmetics and nail systems that historically used some of the photoinitiators / solvents that ride in CMR omnibus waves.
Action now: confirm no live EU placement still carries a 2025/877 Annex II substance.
Official text
Official English extract from Regulation (EU) 2025/877. The full OJ text and annexes prevail.
Commission Regulation (EU) 2025/877 of 12 May 2025 amends Regulation (EC) No 1223/2009 as regards the use in cosmetic products of certain substances classified as carcinogenic, mutagenic or toxic for reproduction.
The regulation aligns the Cosmetics Regulation with CMR classifications under the CLP Regulation by amending the relevant annexes (typically adding substances to Annex II unless a specific exemption is set out).
The updated annex requirements apply from 1 September 2025. Substance identifiers are those listed in the Official Journal annex, not trade names.