Restrictions on Personal Care, Consumer and Professional Products

‘Wash-off’ restriction:

The EU adopted a restriction on the use of D4 and D5 in wash-off cosmetic products under REACH in May 2017.

The scope of the restriction is limited to wash-off cosmetic products with D4 or D5 concentrations equal to or greater than 0.1% by weight of each of these substances. All companies that place products that are within the restriction scope on the European market (including those substances imported to the European market) were required to comply with the requirements set forth in this restriction by January 31, 2020.

In response to this restriction, the silicones industry set up a large-scale Wastewater Treatment Plant (WWTP) monitoring program to help assess the effectiveness of this restriction in reducing D4 and D5 down-the-drain emissions. Monitoring results indicate that D4 and D5 wastewater treatment plant influent concentrations are well below the baseline levels predicted, and in the case of D4, already consistent with the predicted post-restriction concentrations. These concentrations are lower than expected and suggest that the restriction was unnecessary.

‘Leave-on’ restriction proposal:

In April 2017, the European Commission announced its intention to add wash-off uses of D6 use in personal care products to the prior restriction, and assess the need for a further restriction of D4, D5 and D6 in leave-on personal care products and other consumer/professional uses (e.g. dry cleaning, waxes and polishes, washing and cleaning products).

EU regulators have imposed a REACH restriction on the use of D4, D5 and D6 in leave-on and personal care applications as well as consumer and professional applications in a concentration equal to or greater than 0.1% w/w of each substance. The EU adopted this restriction, effective June 2026.

Substances of Very High Concern

The silicones industry believes that D4, D5, and D6 as SVHCs, ECHA do not meet the criteria of vPvB and PBT substances.

Draft Authorization Proposal

ECHA has identified D4, D5, and D6 in its draft recommendation as potential candidates for an authorization requirement.

Cosmetics and Siloxanes

Learn about Annex II of the EU Cosmetics Regulation.