UK SAG-CS Releases Final Safety Opinions on Seven Cosmetic Ingredients

In August 2026, the UK Scientific Advisory Group on Chemical Safety of Non-Food and Non-Medicinal Consumer Products (SAG-CS) published seven final safety opinions on cosmetic ingredients, covering Triclocarban, Triclosan, O-phenylphenol (OPP), Sodium o-phenylphenate (SOPP), Resorcinol, Daidzein, and Silver. CIRS Group has compiled the SAG-CS conclusions and provided a regulatory interpretation for each ingredient for your reference.

I. Triclocarban (Opinion 20)

SAG-CS Conclusions:

The SAG-CS concluded that Triclocarban is safe for use at the following concentrations and in the corresponding product types as a preservative:

• In rinse-off products for use by adults: maximum concentration 1.5%
• In all cosmetic products (excluding mouthwash for all age groups and children's toothpaste): maximum concentration 0.2%

The SAG-CS agreed with the SCCS conclusion that the use of Triclocarban at 0.2% in mouthwashes for children, adolescents, and adults, and in toothpastes for children below 6 years of age at 0.2%, could cause the aggregate exposure to Triclocarban to exceed acceptable margins of safety. The SAG-CS were of the opinion that a full risk assessment in children and adolescents should be conducted when adequate data and an appropriate methodology become available.

Regulatory Interpretation:

In China, Triclocarban (CAS No. 101-20-2) is listed in the Inventory of Existing Cosmetic Ingredients in China (IECIC I) and the List of Allowed Preservatives, with a maximum permitted concentration of 0.2%.

In the UK, Triclocarban is listed in the Cosmetic Products Regulation UK No 1223/2009:

• Annex III (Restricted Substances): maximum concentration 1.5% in rinse-off products
• Annex V (Allowed Preservatives): maximum concentration 0.2%

In the EU, triclocarban is listed in the Cosmetic Products Regulation (EC) No 1223/2009:

• Annex III (Restricted Substances): maximum concentration 1.5% in rinse-off products
• Annex V (Allowed Preservatives): maximum concentration 0.2% in all cosmetic products (excluding mouthwash)

II. Sodium o-Phenylphenate (Opinion 21)

SAG-CS Conclusions:

The SAG-CS concluded that Sodium o-phenylphenate is acceptable for use in the following cosmetic product types (excluding oral care and spray products) at the following concentrations:

• Rinse-off products: 0.2%
• Leave-on products: 0.15%

When used together with o-Phenylphenol (OPP), the combined concentration of Sodium o-phenylphenate and o-Phenylphenol should not exceed the above maximum concentration limits. Oral care products and spray products are excluded from this safety assessment. The SAG-CS were of the opinion that a full risk assessment in children and adolescents should be conducted when adequate data and an appropriate methodology become available.

Regulatory Interpretation:

In China, Sodium o-phenylphenate (CAS No. 132-27-4) is listed in the IECIC I and the List of Allowed Preservatives, with a maximum permitted concentration of 0.2% in total (as phenol).

Note: On 15 May 2026, the NMPA issued an announcement revising the standard for "o-Phenylphenol and Its Salts", effective from 1 June 2028. The revision introduces differentiated management by product type ("leave-on products" vs "rinse-off products") with respective maximum permitted concentrations, and adds a mandatory label warning: "avoid contact with eyes".

In the UK, Sodium o-phenylphenate is not listed in Annex V of the Cosmetic Products Regulation UK No 1223/2009 and is therefore not currently permitted for use as a preservative in cosmetic products.

In the EU, Sodium o-phenylphenate is listed in Annex V (Allowed Preservatives) of the Cosmetic Products Regulation (EC) No 1223/2009:

• Rinse-off products: maximum concentration 0.2% (as phenol)
• Leave-on products: maximum concentration 0.15% (as phenol)

When O-phenylphenol and Sodium o-phenylphenate are used together, the combined concentration shall not exceed 0.2% (as phenol) in rinse-off products and 0.15% (as phenol) in leave-on products. Shall not be used in products that may result in inhalation exposure by the end user. Shall not be used in oral care products.

III. Triclosan (Opinion 22)

SAG-CS Conclusions:

The SAG-CS concluded that Triclosan is safe for preservative use at the following concentrations and in the corresponding product types:

• In mouthwashes: maximum concentration 0.2%
• In toothpastes, hand soaps, body soaps/shower gels, deodorants (non-spray), face powders and blemish concealers, and nail products for cleaning finger and toenails before the application of artificial nail systems: maximum concentration 0.3%

The SAG-CS were of the opinion that a full risk assessment in children and adolescents should be conducted when adequate data and an appropriate methodology become available.

Regulatory Interpretation:

In China, Triclosan (CAS No. 3380-34-5) is listed in the IECIC I and the List of Allowed Preservatives, with a maximum permitted concentration of 0.3%. The applicable product types and conditions of use are: hand soaps, bath soaps, body washes, deodorants (non-spray), face powders and blemish concealers, and nail cleaning products (nail cleaning products shall not be used more frequently than once every two weeks).

In the UK, Triclosan is currently listed in Annex V (Allowed Preservatives) of the Cosmetic Products Regulation UK No 1223/2009:

• In mouthwashes: maximum concentration 0.2%
• In toothpastes, hand soaps, body soaps/shower gels, deodorants (non-spray), face powders, blemish concealers, and nail products for cleaning finger and toenails before the application of artificial nail systems: maximum concentration 0.3%

In the EU, Triclosan is listed in Annex V (Allowed Preservatives) of the Cosmetic Products Regulation (EC) No 1223/2009, with a maximum concentration of 0.3% in toothpastes, hand soaps, body soaps/shower gels, deodorants (non-spray), face powders, blemish concealers, and nail products for cleaning finger and toenails before the application of artificial nail systems. Toothpastes containing Triclosan must bear the warning: "Do not use for children under 3 years of age".

IV. Daidzein (Opinion 23)

SAG-CS Conclusions:

The SAG-CS concluded that Daidzein is safe for use in cosmetic products up to a maximum concentration of 0.02% w/w. This conclusion is based on available published data in the absence of any additional data submitted by industry, and concurs with the SCCS conclusion.

Regulatory Interpretation:

Daidzein (CAS No. 486-66-8) is currently not listed in the IECIC or the Cosmetic Products Regulation UK No 1223/2009. In the EU, Daidzein is listed in Annex III (Restricted Substances) of the Cosmetic Products Regulation (EC) No 1223/2009, with a maximum permitted concentration of 0.02%.

V. o-Phenylphenol (OPP) (Opinion 24)

SAG-CS Conclusions:

The SAG-CS concluded that o-Phenylphenol (OPP) is acceptable for use in the following cosmetic product types at the following concentrations:

• All rinse-off products: 0.2%
• All leave-on products: 0.15%

When used together with sodium o-Phenylphenate, the combined concentration of o-Phenylphenol and Sodium o-phenylphenate should not exceed the above maximum concentration limits. Oral care products and spray products are excluded from this safety assessment. The SAG-CS were of the opinion that a full risk assessment in children and adolescents should be conducted when adequate data and an appropriate methodology become available.

Regulatory Interpretation:

In China, o-Phenylphenol (CAS No. 90-43-7) is listed in the IECIC I and the List of Allowed Preservatives, with a maximum permitted concentration of 0.2% in total (as phenol).

Note: On 15 May 2026, the NMPA issued an announcement revising the standard for "o-Phenylphenol and Its Salts", effective from 1 June 2028. The revision introduces differentiated management by product type ("leave-on products" vs "rinse-off products") with respective maximum permitted concentrations, and adds a mandatory label warning: "avoid contact with eyes". (See the section on Sodium o-Phenylphenate above for details.)

In the UK, o-Phenylphenol is listed in Annex V (Allowed Preservatives) of the Cosmetic Products Regulation UK No 1223/2009:

• Rinse-off products: maximum concentration 0.2%
• Leave-on products: maximum concentration 0.15%

In the EU, o-Phenylphenol is listed in Annex V (Allowed Preservatives) of the Cosmetic Products Regulation (EC) No 1223/2009:

• Rinse-off products: maximum concentration 0.2% (as phenol)
• Leave-on products: maximum concentration 0.15% (as phenol)

When o-Phenylphenol and Sodium o-phenylphenate are used together, the combined concentration shall not exceed 0.2% (as phenol) in rinse-off products and 0.15% (as phenol) in leave-on products. Shall not be used in products that may result in inhalation exposure by the end user. Shall not be used in oral care products.

VI. Resorcinol (Opinion 25)

SAG-CS Conclusions:

The SAG-CS concluded that Resorcinol is acceptable for use as a cosmetic ingredient in the following product types, subject to the conditions of use to be printed on the label as already stipulated in the Cosmetic Products Regulation:

• Oxidative hair dye products intended for the hair and to colour eyelashes: maximum on-head concentration of 1.25%
• Hair lotions and shampoos: 0.5%

Regulatory Interpretation:

In China, resorcinol (CAS No. 108-46-3) is listed in:

• IECIC I
• List of Restricted Cosmetic Ingredients: maximum concentration 0.5%, with mandatory label conditions: "contains Resorcinol", applicable to hair lotions and shampoos
• List of Allowed Hair Dye Substances: maximum concentration 1.25% in oxidative hair dye products, with mandatory label indication: "contains resorcinol"

In the UK, Resorcinol is listed in Annex III (Restricted Substances) of the Cosmetic Products Regulation UK No 1223/2009:

• For oxidative hair dye products, maximum on-head concentration of 1.25% when mixed under oxidative conditions and applied to hair or eyelashes
• For hair lotions and shampoos: maximum concentration 0.5%
• Hair dye products containing Resorcinol shall bear label conditions of use, including: "Not suitable for persons under 16 years of age." Products for colouring eyelashes are for professional use only.

In the EU, Resorcinol is listed in Annex III (Restricted Substances) of the Cosmetic Products Regulation (EC) No 1223/2009:

• Oxidative hair dye products and products for colouring eyelashes (professional use only): maximum concentration 1.25% when mixed under oxidative conditions and applied to hair or eyelashes
• Hair lotions and shampoos: maximum concentration 0.5%

VII. Micron-sized Particulate Silver (Opinion 26)

SAG-CS Conclusions:

The SAG-CS concluded that micron-sized particulate silver (particle diameter >100 nm and <1 mm) is acceptable for use in cosmetic products at the following maximum concentrations:

• Leave-on cosmetics (excluding lip products): 0.3%
• Lip products: 0.2%
• Rinse-off cosmetics (excluding mouthwash and toothpaste): 0.3%
• Mouthwash and toothpaste: 0.05%

The use of micron-sized particulate silver in propellant sprays is excluded from the conclusions as this product type was not included in the applicant dossier. The SAG-CS were of the opinion that a full risk assessment in children and adolescents should be conducted when adequate data and an appropriate methodology become available.

Regulatory Interpretation:

In China, Silver (CAS No. 7440-22-4) is listed in the IECIC I and the List of Allowed Colorants, and is permitted for use in various cosmetic products.

In the UK, Silver is listed in Annex IV (Allowed Colorants) of the Cosmetic Products Regulation UK No 1223/2009, with no maximum concentration specified.

In the EU, all forms of elemental silver have been classified as Category 2 CMR substances under the GB CLP Regulation via Delegated Regulation (EU) 2024/2564, covering the following particle size ranges:

• Massive silver (particle diameter ≥1 mm)
• Micron-sized particulate silver (silver powder) (particle diameter >100 nm and <1 mm)
• Nano-silver (particle diameter >1 nm and ≤100 nm)

On 30 July 2026, the European Commission submitted WTO notification G/TBT/N/EU/1227, proposing to amend the restrictions and control requirements for micron-sized particulate silver under the Cosmetic Products Regulation (EC) No 1223/2009.

CIRS Interpretation: EU Proposes to Further Update the Usage Requirement for Micron-sized Silver

SAG-CS