The European Union has introduced new restrictions affecting EU hair dye regulation and future OEM color projects. Commission Regulation (EU) 2026/909, adopted on April 27 and published on April 28, 2026, updates the EU Cosmetics Regulation for 12 ingredients. Four newly restricted substances are used in hair dyes, making formula screening and label review a priority for brands, distributors, and salon-supply buyers.

Four Hair Dye Ingredients to Check

The regulation adds specific maximum on-head concentrations for these substances:

• HC Blue No. 18: up to 0.35% in both oxidative and non-oxidative hair dye products.
• Hydroxypropyl-p-phenylenediamine and its 2HCl salt: up to 2% after mixing under oxidative conditions.
• HC Yellow No. 16: up to 1% after oxidative mixing and 1.5% in non-oxidative products.
• HC Red No. 18: up to 1.5% after oxidative mixing and 0.5% in non-oxidative products.

For the oxidative uses listed in the regulation, the label must state the mixing ratio and carry the required hair-colorant allergy warnings. Buyers should not compare only the raw-material percentage on a supplier sheet: the legal limit can apply to the concentration placed on the hair after the color cream and developer are mixed.

The Transition Deadline Matters Now

According to the official EU notice, cosmetic products that do not comply with the new requirements may be placed on the Union market only until January 1, 2027. Existing non-compliant products may remain available on the market until July 1, 2028.

That schedule creates a short planning window. Approving samples, cartons, and production before checking the updated Annex III entries could lead to formula changes, artwork revisions, or blocked inventory.

What OEM Buyers Should Request

Before approving an EU-bound hair-color order, align with the hair color manufacturer on five records:

• Final INCI list and CAS identification for every proposed shade.
• On-head concentration calculations after the intended mixing ratio.
• Written confirmation of whether the product is oxidative or non-oxidative.
• Label text, cautions, and mixing directions for the destination languages.
• A change-control process connecting the approved sample, formula, and packaging version.

Check each shade separately because different colors may use different dye intermediates or direct colorants.

Build Compliance into the OEM Brief

Famo Kemei Innovation (Guangdong) Cosmetics Co., Ltd. supports OEM, ODM, and OBM discussions for hair color, perm, bleaching, and hair-care products. For an EU project, the buyer should provide the sales market, product type, shade plan, mixing ratio, pack size, artwork languages, and launch schedule. Formula, label, and documentation requirements are then confirmed for the individual project rather than assumed from a generic claim.

Review our hair color cream range or contact our team with your EU market and shade brief for a project-specific discussion.

Company Information

Company: Famo Kemei Innovation (Guangdong) Cosmetics Co., Ltd.
Contact: Ted, Founder & CEO
Phone / WhatsApp / WeChat: +86 183 4438 3713
Address: 2nd to 3rd Floor, Building D5-3, East of Gongye Avenue, South of Hengsi Road, Zhongqu, Qinghuayuan, Donghua Town, Yingde City, Qingyuan City, Guangdong Province, China

Authoritative Sources

• EUR-Lex: Commission Regulation (EU) 2026/909
• European Commission: Cosmetics legislation

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