Hair Care & Styling

Hair care spans rinse-off shampoos and conditioners, leave-on styling products and oxidative colourants, and the regulatory weight is not spread evenly across them. A conditioner is a relatively straightforward rinse-off assessment; an oxidative dye, an aerosol and a keratin straightening treatment each carry specific controls that dominate the work.

Oxidative hair dyes

Hair dyes are the most heavily regulated part of the category. Only substances on the dedicated hair-dye entries of Annex III may be used as oxidative colourants, each at a listed maximum concentration and under listed conditions, the product of a specific EU safety-assessment programme for hair-dye substances. Strong sensitisers such as p-phenylenediamine and toluene-2,5-diamine are permitted only within those limits, and resorcinol and related couplers are similarly constrained. The label must carry the prescribed allergy warning, advise against use on eyebrows and eyelashes, and recommend an allergy-alert test before each use; the mixing ratio and the developer have to be assessed as the product is actually used.

Sensitisation

Hair colourants are among the strongest skin sensitisers in cosmetics, so the safety report addresses skin sensitisation directly rather than as a general endpoint, and the warnings, gloves and instructions that manage that risk are part of the assessed product, not optional additions.

Aerosols and propellants

Styling sprays, mousses and dry shampoos are pressurised products, so they sit under the Aerosol Dispensers Directive 75/324/EEC, and the GB Aerosol Dispensers Regulations 2009, alongside the Cosmetics Regulation. That brings flammability classification, pressure and the aerosol-specific labelling into scope on top of the cosmetic requirements. The flammable hydrocarbon propellants used (butane, propane, isobutane) must be controlled for impurities; recent benzene findings in dry shampoos traced to propellant impurity are exactly the kind of trace contamination the safety report has to address under the Annex I treatment of impurities and traces.

Straightening and formaldehyde

Keratin and “Brazilian” straightening treatments can release formaldehyde, which is prohibited as an intentionally added ingredient. The labelling threshold for formaldehyde released by other substances has been lowered to 0.001%, so a treatment that releases formaldehyde above that level must be declared, and a product that releases it in use needs careful assessment of the salon and consumer exposure, including inhalation.

Banned and reformulated

Butylphenyl methylpropional, known as Lilial, was prohibited from 1 March 2022 and had been widespread in shampoos and conditioners as a fragrance, a reminder that the category is exposed to fragrance-allergen and CMR reclassifications as much as to its own specific rules.

How we help

We assess hair products to the way they are used, oxidative dyes at their in-use mixing ratio, aerosols for flammability and propellant purity, and straightening treatments for released formaldehyde and inhalation exposure, prepare the dye and aerosol labelling correctly, and keep formulations current as the Annex III and fragrance-allergen entries change.