Cosmetics Business reported on 23 September that foundation reformulation is entering a new era ahead of the EU restriction on the cyclic silicones D5 and D6. Source: https://cosmeticsbusiness.com/foundation-reformulation-new-era-d5-d6-silcone-bans-2027.
The rule itself is not new. Commission Regulation (EU) 2024/1328 was adopted on 16 May 2024 and amends Annex XVII of REACH. What is new is how close the leave-on deadline has become.
From 6 June 2027, D5 (cyclopentasiloxane) and D6 (cyclohexasiloxane) cannot be placed on the EU market in leave-on cosmetic products at a concentration of 0.1% by weight or more. D5 has been limited to the same level in wash-off products since January 2020. D4 is already banned in cosmetics.
A 0.1% ceiling is far below the level at which these silicones do their job, so the practical effect is a phase-out. If your product relies on them, it has to change.
Why foundations are at the centre of this
The Cosmetic Experts, quoted by Cosmetics Business, explain the appeal clearly. D5 and D6 "provide exceptional spreadability, a lightweight, silky feel and excellent pigment distribution." As they evaporate after application, "they leave a smooth, non-greasy finish while contributing to long wear and a soft-focus effect."
Read that list again from a customer's point of view. Slip on application, a weightless feel, even colour, a finish that does not look greasy, staying power and a blurred look on skin. That is not a technical footnote. It is most of what someone means when they say they love a foundation.
This is the heart of the challenge. Swapping an ingredient is a regulatory task. Keeping the texture, wear and shade accuracy your customer is used to is a brand task, and it is the harder of the two.
Foundations are the obvious case, but they are not the only one. Cyclic silicones have been common in primers, tinted moisturisers, complexion products with a silky finish, and leave-on hair serums. If you sell any leave-on product with a slippy, fast-drying feel, check it rather than assume it is fine.
Eight months is shorter than it sounds
The deadline is June 2027, and it is September 2026. That feels like plenty of time. It usually is not, for three reasons.
The first is development. A new base formula has to be developed, compared against the current one on skin, and adjusted until it genuinely matches. If you sell a shade range, every shade needs to behave consistently in the new base, because pigment distribution was one of the things the old silicones were doing for you.
The second is testing. A reformulated product needs stability and compatibility testing with its packaging, and the safety assessment in your product information file has to be updated. None of that can be rushed without risk, and your Responsible Person will need to sign off the new version before it goes on sale.
The third is supply. The restriction applies to placing products on the market, so the compliant version needs to be manufactured and shipped into the EU before the date. Your manufacturer has other clients with the same deadline, and production slots in spring 2027 are likely to be busy. Work backwards from June and the real start date for most brands is now.
The claims question hiding inside the reformulation
A reformulation can also quietly change what you are allowed to say.
If your packaging or product page makes claims about wear time, finish or feel, those claims were substantiated on the current formula. A new formula needs its own evidence. If the new version wears differently, the claim needs to change, and packaging lead times mean that decision has to be made early.
There is an opportunity here too, if it is handled honestly. A brand that reformulates to a silicone-free base can say so, provided the claim is accurate and meets the rules on free-from claims. What it should not do is present a regulatory requirement as a voluntary brand choice. Customers and regulators are both good at spotting that.
What to do this week
Start with an audit. Search every INCI list in your range for cyclopentasiloxane, cyclohexasiloxane and cyclomethicone. Cyclomethicone is a general name that can cover a blend of cyclic silicones, so treat it as a flag to investigate rather than a clean bill of health.
Then ask your manufacturer three direct questions. What is the percentage of D5 or D6 in each affected formula? When can they deliver a compliant alternative that has been stability tested in your packaging? And when is the last date they can produce the current version for EU supply?
Once you have those answers, you can make the real decisions. Which products get reformulated and which get discontinued. Whether the UK and EU versions will diverge, noting that UK REACH is a separate regime and needs to be checked in its own right. And whether the new formula is a chance to fix a complaint customers have had about the old one.
The plain version
The D5 and D6 restriction is not a surprise, and it is not a crisis. It is a known deadline with a long lead time, which is exactly the kind of deadline that small brands tend to miss.
For a foundation brand, the formula is the product. The silicones being phased out are responsible for much of the feel customers buy it for. Getting the new version right takes development, testing, paperwork and a manufacturing slot, and all four have to be finished before June 2027, not started then.
Check your INCI lists now. If D5 or D6 is in something you sell into the EU, your reformulation plan should have a start date on it by the end of the month.