Non-Food HACCP update: product recalls, cosmetics compliance and packaging changes

Several developments during August 2026 provide important lessons for organisations manufacturing cosmetics, personal-care products, packaging and other non-food goods.

On 14 August 2026, the Office for Product Safety and Standards published a recall notice covering two batches of Simple 730ml Kind to Skin Micellar Cleansing Water.

The affected batches may have been microbiologically contaminated, presenting a risk of eye inflammation. The products were withdrawn from the market and recalled from consumers.

This case provides a useful reminder that microbiological hazards are not restricted to food products.

Water-based cosmetics and personal-care products may provide conditions in which microorganisms can survive or grow. Manufacturers therefore need suitable prerequisite programmes to mitigate this risk. These may include:

• Control and monitoring of water quality.
• Suitable preservative systems.
• Preservative-effectiveness or challenge testing.
• Effective cleaning and sanitation.
• Workplace environmental-hygiene controls.
• Microbiological testing.
• Controlled product-release procedures.
• Batch identification and traceability.

Finished-product testing can contribute to verification, but it should not be the only control. 

The fact that the action related to two identified batches demonstrates the value of effective traceability. Manufacturers must be able to quickly identify affected raw materials, production runs, finished products, and customers when a potential safety issue is detected.

Read the OPSS Simple micellar cleansing water recall.

A separate safety report published by OPSS on 20 August concerned Bare Anatomy Anti-Dandruff Shampoo offered through Amazon, eBay, OnBuy and TikTok.

The product was rejected at the border because it contained butylphenyl methylpropional, also known as lilial or BMHCA. This substance is not permitted in cosmetic products because it may harm the reproductive system and cause skin sensitisation.

Three allergenic fragrance substances were also detected above the labelling threshold for rinse-off products but had not been included in the ingredients list.

This case highlights the importance of:

• Approved and accurate product formulations.
• Reliable information from raw-material and fragrance suppliers.
• Restricted-substance checks.
• Reconciliation of formulations and product specifications.
• Verification of ingredient lists and product artwork.
• Positive product-release procedures.
• Effective controls over imported and contract-manufactured products.

Supplier declarations are important, but manufacturers, importers and responsible persons must still establish whether further verification is required. The nature of the product, the reliability of the supplier and the potential consequences of non-compliance should all be considered.

The involvement of several online marketplaces also demonstrates that products sold through digital and social-commerce channels remain subject to the same product-safety and compliance requirements as products supplied through conventional retailers.

Read the OPSS Bare Anatomy Anti-Dandruff Shampoo safety report.

A sunscreen pack imported from the United States was also rejected at the UK border during August.

According to the OPSS report, the Bubble Cosmetics Sunscreen Pack did not include all the mandatory instructions for sunscreen use or the required product-traceability information.

Labelling and artwork approval should not be treated simply as marketing or administrative activities. They form part of the product’s safety-control system.

Labels may communicate:

• Directions for safe use.
• Warnings and precautions.
• Ingredient and allergen information.
• Storage requirements.
• Batch or product identification.
• Responsible-person information.
• Information needed to support effective traceability.

A failure in any of these areas can make a product unsafe or non-compliant even when the formulation itself is satisfactory.

Artwork approval should therefore be included within documented change-control and product-release arrangements. The approved formulation, product specification, safety assessment and final label should all be reconciled before the product is placed on the market.

Read the OPSS Bubble Cosmetics Sunscreen Pack safety report.

New Great Britain restrictions applying to hexyl salicylate came into force on 15 August 2026.

Hexyl salicylate is used as a fragrance ingredient in a range of cosmetic and personal-care products. The permitted concentration now depends on the type of product and, in some cases, its intended user group.

This reinforces the need for manufacturers and brand owners to obtain accurate composition and concentration information from fragrance suppliers.

Businesses should ensure that change-control arrangements connect all the relevant activities, including:

• Supplier information.
• Formulation review.
• Product safety assessment.
• Product specifications.
• Manufacturing instructions.
• Labelling and artwork.
• Product notification.
• Stock control and segregation.

Organisations supplying different markets must also take care not to assume that the requirements in Great Britain, Northern Ireland and the European Union are identical.

Read The Cosmetic Products Regulation (EC) No 1223/2009 (Restriction of Chemical Substances) (Amendment) Regulations 2026.

Defra updated its extended producer responsibility guidance for packaging on 19 August 2026.

The revised guidance provides further clarification about the activities that may make an organisation an obligated packaging producer.

Importantly, a business may retain producer responsibilities when another organisation manufactures or packs products that will be sold in its branded packaging. Contract manufacturing does not automatically transfer responsibility away from the brand owner.

Manufacturers and brand owners need reliable information about:

• Packaging materials.
• Packaging weight.
• Packaging format and components.
• Whether packaging is primary, secondary or tertiary.
• The way products and packaging enter the supply chain.
• The organisation responsible for each packaging activity.
• Packaging supplied in different UK nations.

Many of these requirements depend upon accurate and controlled specifications.

The same specification-management system can support product safety, HACCP, traceability, legal compliance and environmental reporting. Packaging changes should therefore be reviewed for all their potential consequences rather than being considered by different departments in isolation.

Read the updated Defra guidance on EPR responsibilities and reporting requirements for large producers.

Initial requirements of the EU Packaging and Packaging Waste Regulation began to apply on 12 August 2026.

The Regulation affects UK manufacturers exporting packaged products to the European Union. It covers primary, secondary, tertiary and service packaging and includes requirements connected with recyclability, labelling, recycled content, reuse and the avoidance of unnecessary packaging and harmful substances.

Government export guidance advises businesses to prepare a Declaration of Conformity for each packaging type placed on the EU market from 12 August 2026 and retain the technical documentation required to demonstrate compliance.

This is particularly relevant to UK manufacturers of cosmetics, personal-care products, detergents, car-care products and other packaged non-food goods.

Packaging assessments and specifications should now support both product-safety requirements and the relevant environmental and market-access obligations.

Read the government’s guidance for UK businesses on the EU Packaging and Packaging Waste Regulation.

These developments suggest several practical questions for manufacturers:

1. Are microbiological hazards adequately considered for water-based products?
2. Are water quality, preservation, hygiene and bulk-storage controls properly defined?
3. Is supplier information independently verified where the level of risk justifies it?
4. Are formulations checked against current restricted-substance requirements?
5. Are labels and artwork included within product-safety and change-control procedures?
6. Can raw materials and finished products be traced accurately by batch?
7. Are packaging specifications complete, accurate and controlled?
8. Have responsibilities for UK packaging EPR been clearly established?
9. Do products exported to the EU meet the applicable packaging requirements?
10. Are HACCP plans reviewed when regulations, formulations, suppliers, processes or packaging change?

HACCP provides a structured method for identifying potential hazards, evaluating risk and establishing controls before problems occur.

RI Training provides practical Non-Food HACCP training for people responsible for developing, implementing and maintaining HACCP systems.

Our bespoke programmes can be adapted for manufacturers of:

• Personal-care and cosmetic products.
• Car-care products.
• Detergents and household cleaning products.
• Packaging.
• Plastic bags and bin liners.
• Laundry products and services.
• Other manufactured non-food goods.

Participants apply HACCP principles and development tools to their own products and processes, helping them turn hazard analysis into practical workplace controls.

Contact us to discuss a bespoke Non-Food HACCP programme for your organisation.