EU Hair Dye Ingredients 2026: New Restrictions for HC Blue, HC Yellow & More
Introduction
The most technically demanding part of EU hair dye regulation is ingredient compliance. The EU operates a “positive list” system: if an ingredient is not explicitly permitted—or is restricted—in the Annexes to Regulation (EC) No 1223/2009, it cannot be used. This differs from many markets where finished products are the primary focus.
Understanding these lists well—particularly Annex II (prohibited), Annex III (restricted), and Annex IV (permitted colorants)—is essential for hair dye wholesalers and manufacturers. The 2026 updates to these Annexes have introduced significant changes that every hair color ODM and manufacturer must address.
This article provides a deep dive into the 2026 ingredient restrictions affecting hair dyes, with a particular focus on the four newly regulated hair dye colorants and the substances affected by the prohibition and restriction updates.
The Four Newly Regulated Hair Dye Colorants
Commission Regulation (EU) 2026/909 added four new hair dye colorants to Annex III of Regulation (EC) No 1223/2009. These substances are subject to immediate application from May 18, 2026, with no transitional period.
| Ingredient | Regulatory status | Key concentration limit | Compliance date |
|---|---|---|---|
| HC Blue No. 18 | Newly restricted (Annex III) | Defined maximum usage levels | Immediate — 18 May 2026 |
| HC Yellow No. 16 | Newly restricted (Annex III) | ≤ 1% (oxidative); ≤ 1.5% (non-oxidative) + allergy warning labeling | Immediate — 18 May 2026 |
| HC Red No. 18 | Newly restricted (Annex III) | Specific concentration limits apply | Immediate — 18 May 2026 |
| Hydroxypropyl-p-phenylenediamine (and its 2HCl salt) | Newly restricted (Annex III) | Maximum 0.35% on-head (dye intermediate in oxidative formulations) | Immediate — 18 May 2026 |
HC Blue No. 18
HC Blue No. 18 is a direct dye used in hair coloring products. Under the new regulation it is added to Annex III with defined maximum usage levels. Hair dye manufacturers using this ingredient must ensure their formulations comply with the new concentration limits immediately.
HC Yellow No. 16
HC Yellow No. 16 is newly permitted for use in hair dye products, with specific maximum concentration limits:
- Oxidative hair dye products: ≤ 1%
- Non-oxidative hair dye products: ≤ 1.5%
Products containing HC Yellow No. 16 must also carry allergy warning labeling.
HC Red No. 18
HC Red No. 18 is added to Annex III as a newly regulated hair dye colorant. Specific concentration limits apply, and hair dye manufacturers must verify compliance.
Hydroxypropyl-p-phenylenediamine (and its 2HCl salt)
Hydroxypropyl-p-phenylenediamine, including its dihydrochloride salt form, is added to Annex III with a maximum on-head concentration of 0.35%. This substance is used as a dye intermediate in oxidative hair dye formulations.
Because these restrictive clauses apply immediately from May 18, 2026, any products containing these ingredients supplied by hair dye ODM providers and manufacturers must be reformulated or verified for compliance before being placed on the EU market.
- 18 May 2026 — New Annex III restrictions apply immediately (no transition period)
- 1 January 2027 — Triphenyl Phosphate products may no longer be placed on the EU market
- 1 July 2028 — Triphenyl Phosphate products must be fully withdrawn from the EU market
SCCS Opinions: Basic Brown 16 and Basic Blue 99
Beyond Regulation (EU) 2026/909, the Scientific Committee on Consumer Safety (SCCS) has issued significant opinions on other hair dye ingredients. On January 10, 2026, the SCCS published its final opinions on Basic Brown 16 (C009) (CAS No. 26381-41-9) (SCCS/1684/25) and Basic Blue 99 (C059) (CAS No. 68123-13-7) (SCCS/1683/25).
Basic Brown 16 (C009)
The SCCS does not consider the use of Basic Brown 16 safe as an ingredient in non-oxidative hair dye formulations, because the weight of evidence indicates its potential for mutagenicity.
Basic Blue 99 (C059)
The SCCS does not consider the use of Basic Blue 99 safe as an ingredient in non-oxidative hair dye formulations, because the collective evidence indicates a potential for genotoxicity. The SCCS also regards Basic Blue 99 as a skin sensitizer.
These opinions align with the preliminary scientific opinion published on November 17, 2025. While these substances have not yet been formally banned, these SCCS opinions signal that regulatory action may follow. Hair dye manufacturers and suppliers should reformulate products that rely on these ingredients, particularly for non-oxidative hair dye applications. Note that in China, Basic Brown 16 and Basic Blue 99 remain allowed in cosmetic products today.
Triphenyl Phosphate: Banned Substance
Triphenyl Phosphate has been added to Annex II (the list of prohibited substances) because there is insufficient data to rule out genotoxicity. The ban is based on the SCCS opinion from July 2024 and applies to all cosmetics containing Triphenyl Phosphate, especially hair dyes.
- Must not be placed on the EU market after January 1, 2027
- Must be withdrawn from the EU market after July 1, 2028
Hair dye manufacturers and suppliers should identify any formulations containing Triphenyl Phosphate and begin reformulation immediately.
Other Restricted Substances Affecting Hair Dyes
Citral
Citral (including Geranial and Neral) is a fragrance allergen commonly found in hair dye products. Regulation (EU) 2026/909 introduces new maximum concentration limits for Citral, varying by product category. For hair products, the maximum concentration is 1.2%. The existing allergen labeling requirements are retained.
Benzyl Salicylate
New maximum usage levels for Benzyl Salicylate have been introduced, depending on product category. Hair dye manufacturers must verify that their fragrance components comply with these new limits.
Aluminum-Containing Ingredients
New concentration limits have been introduced for aluminum-containing ingredients across different cosmetic categories. Hair dye products containing aluminum-based ingredients should be reviewed.
Practical Compliance Steps for Hair Dye Manufacturers
Based on the regulatory requirements, hair color manufacturers and suppliers should take the following steps:
- Review all formulations to check whether they contain any of the four newly regulated colorants, Triphenyl Phosphate, Citral, Benzyl Salicylate, or aluminum-containing ingredients.
- Check concentration levels to ensure the final formula stays within the applicable limits.
- Update documentation: Product Information Files, safety assessments, and ingredient declarations must be revised to reflect the new regulatory context.
- Verify with raw material suppliers that all ingredients meet the new purity and concentration requirements.
- Plan alternatives: for ingredients facing potential bans (such as Basic Brown 16 and Basic Blue 99, based on SCCS opinions), identify and qualify substitute ingredients that can replace them.
Summary
The 2026 ingredient updates represent a significant shift in EU hair dye regulation. The four newly regulated hair dye colorants—HC Blue No. 18, HC Yellow No. 16, HC Red No. 18, and Hydroxypropyl-p-phenylenediamine—are subject to immediate compliance from May 18, 2026. At the same time, Triphenyl Phosphate can no longer be used, while substances like Citral and Benzyl Salicylate face new concentration limits.
To maintain EU market access, hair dye manufacturers, hair color ODM providers, and suppliers should immediately conduct active ingredient reviews and formula adjustments. As the SCCS continues to evaluate hair dye ingredients, further changes are likely.
Frequently Asked Questions
When do the new restrictions on HC Blue No. 18, HC Yellow No. 16, HC Red No. 18 and Hydroxypropyl-p-phenylenediamine apply?
These four hair dye colorants were added to Annex III of Regulation (EC) No 1223/2009 by Commission Regulation (EU) 2026/909 and are subject to immediate application from 18 May 2026, with no transitional period.
What is the maximum concentration of HC Yellow No. 16 in hair dyes?
HC Yellow No. 16 is limited to 1% in oxidative hair dyes and 1.5% in non-oxidative hair dyes. Products containing it must also carry allergy warning labeling.
When must products containing Triphenyl Phosphate leave the EU market?
Triphenyl Phosphate is prohibited under Annex II. Products containing it may not be placed on the EU market after 1 January 2027 and must be fully withdrawn by 1 July 2028.
Sources
European Commission, Regulation (EU) 2026/909, Official Journal of the European Union L, April 28, 2026
Complife Group, “Omnibus 2 on cosmetic ingredients,” June 16, 2026
CIRS Group, “SCCS Issued Final Opinion on Hair Dye Basic Brown 16 (C009) and Basic Blue 99 (C059),” January 10, 2026
J.S. Hamilton, “EU Regulation 2026/909: New Challenges,” June 23, 2026
Shandong Provincial Department of Commerce, “欧盟修订化妆品法规,” May 18, 2026
