The European cosmetics industry is facing significant regulatory changes that will impact product formulations containing metallic silver. If you’re a cosmetic formulator working with silver-based ingredients, understanding these upcoming restrictions is essential to maintaining market access in the EU.
What’s Being Banned and Restricted?
Nano Silver Ban (Already in Effect)
Under Commission Regulation (EU) 2024/858, published on March 15, 2024, colloidal silver (nano) has been added to Annex II of the EU Cosmetics Regulation (EC) No 1223/2009. This means silver in nanomaterial form (particles between 1-100 nanometers) is now completely prohibited in cosmetic products sold in the European Union.
The regulation specifically targets colloidal silver (nano) with CAS number 7440-22-4, along with several other metallic nanomaterials including copper, gold, and platinum in their nano forms.
Non-Nano Silver Restrictions Coming May 2026
Critical Update: A new restriction is coming for larger silver particles. Under the draft Omnibus Act VIII, silver powder with particle sizes between 100 nanometers and 1 millimeter will be added to Annex III as a restricted substance, not a completely banned substance.
According to the SCCS Opinion (SCCS/1665/24) issued in June 2024, micron-sized particulate silver was found to be unsafe at higher concentrations in most cosmetic applications. However, limited use in specific products is permitted under strict conditions.
Key Compliance Deadlines
Nano Silver (Colloidal Silver Nano)
February 1, 2025: Manufacturers can no longer place cosmetic products containing colloidal silver (nano) on the EU market. This is your last opportunity to introduce products with these ingredients.
November 1, 2025: Complete market withdrawal deadline. All cosmetic products containing colloidal silver (nano) must be removed from distribution channels, retail shelves, and online marketplaces throughout the European Union.
Non-Nano Silver Powder (100nm – 1mm particle size)
May 1, 2026: The new restriction on silver powder (particle diameter between 100 nanometers and 1 millimeter) takes effect. Unlike nano silver which is completely banned, this form of silver will be allowed ONLY in specific products at very low concentrations:
- Toothpaste: ≤0.05% concentration
- Mouthwash: ≤0.05% concentration
- Eye shadow: ≤0.2% concentration (as colorant)
- Lip products: ≤0.2% concentration (as colorant)
All other cosmetic products containing silver powder in this particle size range must be reformulated or withdrawn from the market by this date. There is no distinction between “placing on the market” and “making available” for this deadline—non-compliant products must be completely withdrawn by May 1, 2026.
PLEASE READ THE LATEST UPDATE ABOUT NON NANO SILVER HERE
If using Silver as a natural antimicrobial you can explore alternatives in the Green Chem Finder compendium