p‑Cymene and Cuminaldehyde, two constituents widely present in essential oils, extracts, and other Natural Complex Substances (NCS) used in particular in fragrances, are at the center of a new scientific evaluation at European level under Regulation (EC) No 1223/2009.

At the end of July 2026, the European Commission issued two mandates requesting the Scientific Committee on Consumer Safety (SCCS) to assess the safety of p-Cymene and Cuminaldehyde as constituents of NCS used in cosmetics:

• SCCS Mandate on p‑Cymene (CAS No. 99‑87‑6, EC No. 202‑796‑7) as a constituent of NCS.
• SCCS Mandate on Cuminaldehyde (CAS No. 122‑03‑2, EC No. 204‑527‑4) as a constituent of NCS.

The SCCS has been asked to assess whether the substances are safe when present as constituents of NCS at the concentrations proposed in the respective industry dossiers, taking into consideration their possible classification as Reprotoxic Category 1B (Repr. 1B) under the CLP Regulation, or alternatively to determine a maximum safe concentration.

Industry target levels under SCCS Review

The cosmetics industry is not seeking to defend p-Cymene or Cuminaldehyde as standalone cosmetic ingredients (“as such”). Instead, defense dossiers submitted in May 2026 aim to support their safe use when both molecules occur as natural constituents of Natural Complex Substances (NCS), namely complex botanical mixtures where they are inherent to the natural matrix rather than intentionally added as pure substances.

The SCCS has been asked to evaluate specific exposure scenarios to assess the Margin of Safety (MoS) across product types, including distinct thresholds for children under 10 years of age:

Proposed levels for p-Cymene

• Fragrance products: up to 0.30% (adults) | 0.00005% (children < 10 years)
• Leave-on body products: up to 0.080%
• Rinse-off products: up to 0.080% (adults) | 0.005% (children < 10 years)
• Deodorants: up to 0.057%
• Leave-on face products: up to 0.051%
• Leave-on hair products: up to 0.040%
• Lip products: up to 0.024%
• Oral care products: up to 0.022% (adults) | 0.0008% (children < 10 years)
• General leave-on products for children (< 10 years): up to 0.0003%

Proposed levels for Cuminaldehyde

• Leave-on hair products: up to 0.040%
• Fragrance products: up to 0.035% (adults) | 0.00005% (children < 10 years)
• Make-up products (excluding lip products) and make-up removers: up to 0.014%
• Rinse-off products: up to 0.014% (adults) | 0.0002% (children < 10 years)
• Leave-on skin products: up to 0.005%
• Deodorants: up to 0.00314%
• Oral care products: up to 0.0017% (adults) | 0.000002% (children < 10 years)
• Lip products: up to 0.001%
• General leave-on products for children (< 10 years): up to 0.0001%

Note: These lists represent the maximum concentration proposed by industry for SCCS safety assessment. They are not binding legal limits.

Why the SCCS Mandates? CLP CMR 1B and Article 15

The SCCS mandates follow ECHA Risk Assessment Committee (RAC) opinions recommending the classification of p-Cymene and Cuminaldehyde as Reprotoxic Category 1B (Repr. 1B – H360Fd).

This classification directly triggers Article 15(2) of Regulation (EC) No 1223/2009, which governs the use of CMR substances in cosmetics. If the Repr. 1B classification becomes harmonised under Annex VI of the CLP Regulation, their use in cosmetic products could be prohibited unless specific derogation criteria are met.

Against this regulatory background, the SCCS evaluation aims to determine whether p-Cymene and Cuminaldehyde can be safely used at the concentrations proposed by industry, or alternatively to establish maximum safe limits as constituents of NCS, thereby preventing an automatic, blanket prohibition under Article 15.

Timeline and recommendations for manufacturers

Both SCCS mandates provide for a nine-month timeframe for the adoption of the scientific Opinions, with the assessments therefore expected to progress towards Opinions in 2027.

• Scientific evaluation: the SCCS will assess the safety of p-Cymene and Cuminaldehyde as constituents of NCS at the proposed concentrations.
• Preliminary Opinion: where a preliminary Opinion is issued, stakeholders may have an opportunity to submit comments and additional information before final adoption.
• Final Opinion: the SCCS will establish its scientific conclusions, which may confirm safety at the proposed concentrations, identify a different maximum safe concentration, or conclude that the substances cannot be considered safe as constituents of NCS (potentially leading to a total ban under Article 15).
• Regulatory follow-up: any subsequent amendment to the EU Cosmetics Regulation would be a separate step for the European Commission.

This review does not, in itself, introduce an immediate new prohibition or restriction on p-Cymene or Cuminaldehyde in cosmetic products. However, manufacturers should monitor the SCCS assessment and consider the potential impact on formulations, essential oils, fragrance compounds and other NCS ahead of any future regulatory measures.

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SOURCES:

• Request for a scientific Opinion on the safety of p cymene (CAS No. 99-87-6, EC No. 202-796-7)
• Request for a scientific Opinion on the safety of Cuminaldehyde (CAS No. 122-03-2, EC No. 204-527-4) as a constituent of Natural Complex Substances (NCS)