How Long Does a Cosmetic Ingredient Restriction Actually Take? A Real Timeline

Most cosmetic brands only notice a restriction when it appears in an Annex amendment. By that point, the regulatory story may already have been developing for years. The ban is the last step, not the first one.

Lilial, also known as BMHCA (BUTYLPHENYL METHYLPROPIONAL), is a useful example. The process began in 2017, when a dossier was submitted to ECHA to harmonise the classification and labelling of BMHCA under EU chemicals legislation, separate from cosmetics regulation entirely. In 2019, ECHA’s Risk Assessment Committee (RAC) concluded that BMHCA should be classified as toxic to reproduction, Category 1B. The European Commission adopted that classification through Delegated Regulation (EU) 2020/1182 in 2020, adding it to Annex VI of the CLP Regulation. The classification became applicable on 1 March 2022.

This is also where the cosmetics consequences arise. Under Article 15 of Regulation (EC) No 1223/2009, CMR Category 1A and 1B substances are, in principle, prohibited in cosmetic products, subject to the specific derogation mechanism provided by the Regulation. For BMHCA, the Repr. 1B classification ultimately resulted in its use in cosmetics being prohibited from the same date the classification applied, 1 March 2022.

From the initial CLH proposal in 2017 to that application date, the timeline was roughly five years. For most of that period, there was no cosmetics-specific headline to follow, only a chemical classification process moving through the CLP system.

For brands, the practical implication is straightforward. The earliest useful signal often appears upstream, in chemicals legislation, not in a cosmetics Annex. Monitoring CLH proposals, RAC opinions, and CLP amendments for ingredients with potential CMR concern can provide real visibility years before any cosmetic consequence appears. Not every CLH proposal becomes a cosmetic restriction, but understanding which regulatory pathway an ingredient has entered tells you when to start watching its trajectory. Waiting for the Annex to change means starting at the end of the story, not the beginning.

Timeline of CLH process in EU is: