Prohibition and restriction of micro and nanoparticle forms in personal care products
For several months, a European regulatory change has been raising questions among healthcare professionals and cosmetic manufacturers: the use of silver in cosmetic products is now heavily restricted, or even prohibited depending on its form.
At My Podologie, we've broken it down to help you understand the concrete impacts on your products and your practice.
📅 May 1, 2026: a key date
Cosmetic products marketed in Europe are governed by Regulation (EC) No 1223/2009 of the European Union.
This regulation specifies:
- The list of prohibited substances
- The list of restricted substances
- Conditions of use (dosage, product type, target audience)
Recent updates, known as "Omnibus," modify certain annexes, particularly concerning the forms of silver used in cosmetics.
- CMR substances (Carcinogenic, Mutagenic or Reprotoxic) are prohibited in cosmetics, except for strictly regulated derogations.
- Certain nano or particulate forms of silver, depending on their classification and particle size, fall within this scope.
- Non-compliant products will no longer be able to be placed on the market in the EU, including France.
Why is silver concerned?
Silver is used for its properties:
• Antibacterial
• Antifungal
• Sometimes preservative (depending on formulation)
However, in certain forms - particularly nanoparticles - European regulation applies a precautionary principle, especially regarding skin exposure and toxicological assessments.
The decision is based on:
• Safety assessments of nanomaterials
• Environmental concerns
• Uncertainties about prolonged skin absorption
The European objective is to apply the precautionary principle in the cosmetic field.
Which forms of silver are concerned?
It is important to distinguish between the different forms:
1. Colloidal silver (nano form)
Silver nanomaterials (ultra-fine particles) are now prohibited in cosmetic products within the EU.
This concerns products mentioning:
• Silver nano
• Colloidal silver (nano)
• Nanoparticulate silver
2. "Massive" silver (Silver)
Silver in non-nano form, used as a cosmetic ingredient, is also affected by the new restrictions and is now among the prohibited substances for most cosmetic uses.
3. Certain silver powders
In very specific cases (particularly makeup products like for lips or eyelids), tolerances may exist with strict concentration limits.
Application schedule:
The new measures are being applied progressively, with mandatory compliance before May 2026.
As of this date:
• Non-compliant products will no longer be able to be placed on the market.
• Manufacturers will have to reformulate or withdraw the affected products.
👣 Concretely for podiatrists
If you use or market:
• Creams containing silver
• Antimicrobial gels based on silver
• Sprays or "colloidal silver" treatments
These products, containing silver, could:
• Be reformulated by manufacturers
• See their composition modified
• Be gradually withdrawn from the market
🔎 Sources (official)
- EUR-Lex — Regulation (EC) No 1223/2009 (Cosmetic products): CELEX:32009R1223
- European Commission — Cosmetics / regulatory framework: Cosmetics sector page
- SCCS (Scientific Committee on Consumer Safety) — scientific opinions (nanomaterials, including silver according to dossiers): SCCS portal
- CosIng (EU cosmetic ingredients database) — INCI information: CosIng database
- Regulation (EU) 2026/78 — to be found via EUR-Lex (search): EUR-Lex search "2026/78"
