EU ethanol review: what’s being discussed, how the law works, and what health authorities say

Summary: Recent reports say the EU is reviewing a stricter hazard classification for ethanol used in some disinfectants/hand sanitisers (biocides). No final decision has been taken; ECHA’s Biocidal Products Committee (BPC) is scheduled to discuss it in late November 2025 before any European Commission action. Cosmetics (including perfumes) are regulated under a different framework. Reuters+1

Last updated: 26 October 2025.

1) What exactly is on the table?

  • An ECHA working-group recommendation (10 Oct 2025) proposes classifying ethanol as carcinogenic/reprotoxic for biocidal uses, potentially affecting hand sanitisers and certain cleaning products. The BPC will review the evidence in late November 2025 and issue an opinion for the European Commission. No decision yet. Reuters+1
  • Even within biocides, approval can remain possible if exposure is shown to be safe or if no suitable alternatives exist. Reuters

Key point: This is a biocides discussion (disinfectants/hand sanitisers), not a blanket ban on ethanol in all products. Reuters

2) Biocides vs cosmetics: two separate EU laws

  • Biocides: assessed via ECHA committees (e.g., BPC/RAC) under the CLP Regulation (EC No 1272/2008); the European Commission makes final decisions. ECHA
  • Cosmetics (incl. fine fragrance): governed by Regulation (EC) 1223/2009. If a substance later becomes CMR under CLP, Article 15 generally prohibits it unless specific conditions are met—notably a positive SCCS safety opinion and/or lack of suitable alternatives. This is case-by-case; there is no automatic spillover from biocides into cosmetics. EUR-Lex+1

3) What health authorities say about alcohol-based hand hygiene

  • WHO recommends alcohol-based hand rubs (ABHR) for clinical hand hygiene; WHO formulations specify ~80% ethanol (or 75% isopropanol) and remain endorsed with standard safety controls (e.g., flammability management). CNIB
  • ECDC calls for establishing alcohol-based hand disinfection as the primary method in European long-term care/healthcare settings. ECDC
  • US CDC guidance for the public recommends sanitisers with ≥60% alcohol and provides usage technique/duration. CDC

Takeaway: Mainstream health authorities continue to endorse ABHR as a cornerstone of infection prevention while stressing proper technique and handling. CNIB+2ECDC+2

4) Why the EU is reassessing ethanol (in biocides)

The review is about hazard classification under CLP and whether ethanol in biocidal uses should be considered carcinogenic/reprotoxic. ECHA committees assess the totality of evidence (with public input), then the European Commission decides. Hospital-hygiene experts quoted by the Financial Times warn that replacing ethanol could undermine infection control. ECHA+1

5) What a stricter biocide classification could mean—in practice

If the BPC and Commission ultimately support a stricter classification:

  • Biocidal products (e.g., hand sanitisers/cleaners): possible substitution requirements, tighter risk-management, or specific authorisation conditions—though exemptions may exist where exposure is controlled or no viable alternatives exist. Reuters
  • Cosmetics/perfumes: any knock-on effect would be handled under Regulation 1223/2009 via Article 15 (SCCS opinion, defined criteria). The EU regularly amends the cosmetics annexes to reflect CMR updates and exceptions. EUR-Lex+1

6) Our approach (non-promotional note)

Some customers prefer to avoid alcohol in leave-on products for personal or cultural reasons. Earlier this year we introduced a water-based, alcohol-free perfume format to accommodate those preferences, alongside our classic, fully compliant alcohol-based perfumes. We will continue to follow official updates and maintain compliance across all formats. (This note is informational and does not imply any current ban on alcohol-based perfumes.) EUR-Lex

7) Practical timeline & how to follow reliable updates

  • Late Nov 2025: ECHA BPC meeting window reported by major outlets. Afterwards, the opinion goes to the European Commission. Any EU-wide measure would involve drafting, consultation (as applicable), and transition periods. Reuters
  • Follow primary sources: ECHA (CLP/biocides pages), EUR-Lex for Reg. 1223/2009/Article 15, and WHO/ECDC/CDC for hand-hygiene recommendations. CDC+5ECHA+5EUR-Lex+5

Sources

  • Reuters: EU weighs stricter action on ethanol in sanitisers; BPC meeting in late Nov 2025. Reuters
  • Financial Times: sector & hospital-hygiene reactions; committee timing. Financial Times
  • ECHA (biocides/CLP overview); EUR-Lex (EU Cosmetics Regulation 1223/2009; Article 15). ECHA+2EUR-Lex+2
  • WHO: handrub formulations (ethanol ~80%/IPA 75%). CNIB
  • ECDC: hand disinfection as primary method in LTCFs. ECDC
  • CDC: ≥60% alcohol for public hand sanitisers. CDC

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