Global beauty & packaging regulation countdown
30 upcoming deadlines, each with what happens, what to do, the source and a confidence grade.
Timeline
Coming into force
Green = checked against the official text; amber = authoritative secondary source (SGS, Intertek, law firms, official guidance); red = unverified. Tap “What happens · what to do” to expand.
Within 30 days5
🇯🇵 Japan: new Japanese Standards of Quasi-drug Ingredients 2021 become mandatory
What happens · what to do
The revision of 21 March 2025 amended 15 general test methods and 222 ingredient specifications. From 30 September 2026, the new specifications apply unless a minor change notification allowing continued use of the old specifications was filed before September.
What to do: Companies manufacturing or selling quasi-drugs (medicated cosmetics) for Japan should review their raw material specifications.
Source: Pharmaceutical Affairs Notice No. 0321-1 (March 21, 2025) · A related notice was also issued on the same day: Drug Administration and Review Notice No. 0321-1
🇺🇸 US OMUFA FY2027 first instalment due; CMO fee up about 149%
What happens · what to do
The US Food and Drug Administration (FDA) published the FY2027 OTC Monograph Drug User Fee (OMUFA) rates on 29 July 2026: USD 47,891 for monograph drug facilities (MDF) and USD 31,927 for contract manufacturing organisations (CMO), about 149% higher than in FY2026 (FY2026 was an unusually low point following a one-off statutory reserve adjustment). The payment date moves from June to October, with two equal instalments due on 1 October 2026 and 1 February 2027.
What to do: Contract manufacturers producing OTC monograph drugs for US brands (e.g. acne products containing salicylic acid or benzoyl peroxide, and sunscreens) must pay the official CMO fee of USD 31,927, with the first half (USD 15,963.50) due on 1 October 2026. The fee should be factored into the cost of US OTC business. Non-OTC product lines are not affected.
Source: FDA OMUFA
🇮🇩 Indonesia BPOM cosmetic ingredient rules: transition period ends
What happens · what to do
Under Regulation No. 25/2025 of the Indonesian Food and Drug Authority (BPOM): 101 substances are newly prohibited (including Quaternium-15, D4, 2-chloroacetamide and chlorophene); homosalate is restricted to face products (excluding sprays); and benzophenone-3 is restricted by product category. Products containing newly prohibited substances may not be renewed or sold.
What to do: Products on sale in, or being notified for, Indonesia should be checked against the new lists immediately; products that exceed the limits must be reformulated and re-notified.
Source: PerBPOM 25/2025
🇪🇺 EU REACH restriction on PFHxA applies to cosmetics (≥25 ppb)
What happens · what to do
What to do: Under the EU REACH Regulation, companies should check whether formulations and packaging materials contain perfluorohexanoic acid (PFHxA) or its salts.
Source: REACH
🇮🇩 Indonesia: mandatory halal certification for cosmetics takes effect
What happens · what to do
Confirmed by two official sources, the Halal Product Assurance Agency (BPJPH) and the Indonesian Food and Drug Authority (BPOM); the head of BPJPH told parliament there will be no postponement. Imported and domestic products are subject to the same deadline, with no differential treatment. Legal basis: Law No. 33/2014 and Government Regulation No. 42/2024.
What to do: According to a clarification by Indonesia's Minister of Trade on 17 September 2026, halal certification is not an import restriction: goods can clear customs, but a certificate is required for products to be distributed on the market. Indonesian buyers are expected to require manufacturers to provide certification. As of September 2026, Indonesia had signed mutual recognition agreements (MRAs) with 116 foreign halal certification bodies, and certification through an MRA body is generally faster than a new application. Options include: (1) certification by a foreign body that has signed an MRA (first verify that it is on the list); (2) commissioning an Indonesian halal inspection body (LPH) to audit the factory in China. Factories that already hold a halal certificate should also verify that the issuing body is on the MRA list.
Source: Official BPJPH / BPOM
31–90 days2
🇺🇸 California SB 54 plastic packaging EPR: final plan and fee schedule expected
What happens · what to do
The implementing details of California's SB 54 extended producer responsibility (EPR) law for plastic packaging, including the final plan and fee schedule, are expected in October 2026; public comment on the draft closed on 14 August 2026. This is the next key milestone for packaging exported to the US.
What to do: Packaging suppliers and brands with US packaging business should track the fee announcement, as the fees will feed directly into cost calculations.
Source: CalRecycle SB 54 · reviewed 22 Sep
🇨🇳 China GACC Decree No. 284 abolishes filing for export cosmetics manufacturers
What happens · what to do
Decree No. 284 of the General Administration of Customs of China (GACC), published on 6 May 2026, takes effect on 1 December 2026. It also abolishes consignee filing for imported cosmetics and the designated storage site requirement. Pre-export declarations must state that the company holds a production licence and include label samples with Chinese translations. Customs clearance will be considerably simpler, but companies bear greater primary responsibility.
What to do: Exporters can streamline their procedures accordingly, while ensuring that their quality management systems remain effective.
Source: General Administration of Customs Order No. 284 (Issued on May 6, 2026)
91–180 days7
🇪🇺 European Commission due to adopt implementing act on PCR content calculation methodology
What happens · what to do
Under Article 7(8) of the Packaging and Packaging Waste Regulation (PPWR). The methodology will determine whether post-consumer recycled material (PCR) produced in China can count towards EU recycled content targets. Until the methodology is published, no commitment should be made that China-produced PCR will count towards EU targets.
What to do: Packaging suppliers and brands should track the implementing act and refrain from making commitments on this point until the methodology is published.
Source: PPWR Article 7(8)
🇺🇸 Washington State bans 25 formaldehyde-releasing substances, a first among US states
What happens · what to do
Under WAC 173-339-110, 25 formaldehyde-releasing substances will be banned in cosmetics. The list includes DMDM hydantoin, imidazolidinyl urea, diazolidinyl urea and bronopol, which are widely used as low-cost preservatives in products such as cotton pads, wet wipes and sheet-mask essences, so these categories are the most affected. A new definition of 'intentionally added' takes effect on the same date.
What to do: Products sold in Washington State, and products using a single US-wide formula, should switch preservative systems before 1 January 2027 (alternatives include phenoxyethanol with ethylhexylglycerin, caprylyl glycol and hydroxyacetophenone). Preservative changes involve formulation and stability work with long lead times, so brands and manufacturers should start early.
Source: WAC 173-339-110
🇺🇸 Oregon SB 546 bans phthalates, PFAS, formaldehyde and releasers; lead below 10 ppm
What happens · what to do
The Oregon Health Authority (OHA) must review and revise its list of high-priority chemicals every three years, so the list is a living one and one-off compliance will not remain valid.
What to do: Companies should monitor updates to the OHA list of high-priority chemicals.
Source: Oregon SB 546
🇺🇸 Maine bans 13 ingredients; Rhode Island bans intentionally added PFAS in cosmetics
What happens · what to do
Maine's list includes triclocarban and nonylphenol, going further than other states.
Source: 38 MRSA c.37 · RI Consumer PFAS Ban Act
🇨🇳 China industry standard YY/T 10006-2026 on cosmetic product standards takes effect
What happens · what to do
Published by the National Medical Products Administration (NMPA) on 24 August 2026 in Announcement No. 78 of 2026 as the General Rules for Cosmetic Product Standards. The rules for drafting enterprise product standards will change accordingly.
What to do: Companies with filed products should schedule updates to their enterprise standard templates in advance.
Source: NMPA Announcement No. 78 of 2026 · reviewed 22 Sep
🇺🇸 California AB 496 adds 26 banned cosmetic ingredients, including Lilial, D4 and styrene
What happens · what to do
California AB 496 adds 26 ingredients to the state's list of banned cosmetic ingredients, including butylphenyl methylpropional (Lilial), D4 (octamethylcyclotetrasiloxane), styrene and boron compounds, applying from 1 January 2027. It builds on AB 2762, in effect since 1 January 2025, which banned 24 ingredients (11 named substances and 13 PFAS), and AB 2771, which separately bans PFAS as an entire class under a very broad definition (any substance containing at least one fully fluorinated carbon atom). The prohibited activities under current law include holding, so storing non-compliant products in a California warehouse may also be unlawful.
What to do: Brands and manufacturers selling into California should check formulations against the AB 496 additions, and may consider commissioning a third-party testing and certification body to prepare a state-by-state ingredient comparison table.
Source: California AB 496
🇪🇺 EU: EPR participation marks to be digital (QR) only; printed Green Dot phased out
What happens · what to do
What to do: New moulds and printing plates should include a replaceable marking area; otherwise complete sets may have to be scrapped in 2028.
Source: PPWR, Article 12
Beyond 6 months16
🇬🇧 UK Plastic Packaging Tax: pre-consumer scrap no longer counts as recycled content
What happens · what to do
The mass balance approach is introduced on the same date. The 2026/27 rate is GBP 228.82 per tonne, charged where recycled content is below 30%. Packaging that relies on pre-consumer production offcuts to reach 30% will no longer qualify in the UK.
What to do: Packaging suppliers and brands should switch to post-consumer recycled (PCR) material sources and obtain supporting evidence about 12 months in advance.
Source: UK PPT · HMRC
🇪🇺 EU REACH: D4, D5 and D6 limited to 0.1% in all cosmetic products
What happens · what to do
What to do: Review formulations containing cyclosiloxanes.
Source: REACH
🇧🇷 Brazil RDC 1.030/2026 prohibited list: general transition period ends
What happens · what to do
Under RDC 1.030/2026 of Brazil's National Health Surveillance Agency (ANVISA), newly prohibited substances include boric acid and borates, ketoconazole, and Polyurethane-18 and Polyurethane-19. The deadline for reformulating fragrances containing Lilial and Lyral is extended to 11 December 2027. Benzoyl peroxide, hydroquinone and azelaic acid are reclassified from prohibited to restricted.
What to do: Brands and manufacturers of acne-care products may wish to consider the opportunity created by the reclassification of benzoyl peroxide and azelaic acid; the specific concentration limits remain to be confirmed.
Source: ANVISA RDC 1.030/2026
🇧🇷 Brazil animal testing ban: transition period ends (Law No. 15.183/2025)
What happens · what to do
The federal law bans the use of live vertebrate animals in cosmetic testing and prohibits the use of animal test data generated after its entry into force as a basis for approval.
What to do: Ingredient dossiers relying on animal data will no longer be valid in Brazil; ingredient suppliers and brands should assess alternative data sources.
Source: Lei nº 15.183/2025
🇺🇸 US FDA removes PABA and trolamine salicylate from sunscreen monograph M020
What happens · what to do
The US Food and Drug Administration (FDA) issued Final Order OTC000008-1 on 10–11 September 2026, removing aminobenzoic acid (PABA) and trolamine salicylate from sunscreen monograph M020. FDA states that no products currently marketed in the US contain these two ingredients, so the practical impact is limited; however, it is the first time FDA has formally removed previously permitted sunscreen active ingredients, which is a significant signal.
What to do: Companies with US sunscreen lines should watch for further reviews of other active ingredients.
Source: FDA Final Order OTC000008-1 · reviewed 22 Sep
🇪🇺 EU microplastics restriction: rinse-off cosmetic products
What happens · what to do
Phased restriction under Regulation (EU) 2023/2055.
What to do: Review formulations of rinse-off products such as cleansers and scrubs.
Source: Reg (EU) 2023/2055
🇬🇧 GB labels must show a UK Responsible Person address, not only an EU RP
What happens · what to do
Under SI 2022/1393, products whose packaging shows only an EU Responsible Person (EU RP) address can no longer be placed on the Great Britain (GB) market, so packaging artwork will need to change.
What to do: Brands and packaging suppliers serving the UK should plan label changes in advance. Country of origin must be stated accurately; 'Made in EU' or similar wording must not be used where it does not reflect the actual origin.
Source: SI 2022/1393
🇺🇸 California Prop 65: old short-form warnings lose safe harbour
What happens · what to do
The new short-form warning must name at least one chemical; the old format showing only 'WARNING' and the hazard category will no longer qualify for safe harbour. Products manufactured and labelled before 1 January 2028 may continue to be sold indefinitely.
What to do: Brands and packaging suppliers should adopt the new short-form warning (naming a chemical) on new moulds and newly printed packaging; existing labelled stock can be sold through.
Source: Revision to the OEHHA Short Form Warning
🇸🇪 Sweden proposes a national PFAS ban on consumer products, including cosmetics (draft)
What happens · what to do
The Swedish Chemicals Agency draft is open for comment until 30 November 2026, with proposed application from 1 January 2028; it is stricter than EU-level rules.
What to do: Product lines for Sweden and the Nordic market should be assessed early. This is a typical case of a Member State going further than EU-wide rules.
Source: Draft from the Swedish Chemicals Agency · reviewed 22 Sep
🇨🇳 China's mandatory standard GB 7916-2026 on general safety requirements for cosmetics
What happens · what to do
China's first mandatory national standard for cosmetics, published on 6 August 2026, replaces GB 7916-1987, which had been in use for 39 years. Products manufactured or imported before the standard takes effect may be sold until the end of their shelf life.
What to do: With about 17 months between publication and application, brands and manufacturers should use this period to align formulations and labels. Overseas brands exporting to China should also assess the impact.
Source: GB 7916—2026
🇸🇦 Saudi Arabia: sell-through period ends for 3 substances restricted in August 2025
What happens · what to do
Under a Saudi Food and Drug Authority (SFDA) circular, the import and manufacture of non-compliant products have been prohibited since 1 January 2026; products already on the market may be sold until 1 January 2028.
Source: SFDA Circular
🇰🇷 Korea cosmetic safety assessment (similar to EU CPSR): phase 1 begins
What happens · what to do
Phase 1 covers functional cosmetics of companies with annual production or import results of KRW 1 billion or more, as well as newly registered businesses. Phase 2 follows in 2029 (small and medium-sized enterprises, starting with children's cosmetics), with full application in 2031. Note that KRW 1 billion is a threshold based on actual results rather than company size; most brands with real distribution will cross it immediately.
What to do: The raw data needed for safety assessments can generally only come from manufacturers, so Korean brand owners are expected to start requesting technical files equivalent to an EU cosmetic product safety report (CPSR), i.e. a product information file (PIF), from manufacturers before 2028. Factories that already hold EU PIFs can use them directly; those with incomplete documentation have about 18 months to prepare.
Source: 법률 제21302호
🇧🇷 Brazil RDC 1.029/2026 restricted list: transition period for registered products ends
What happens · what to do
Brazil's National Health Surveillance Agency (ANVISA) set a 24-month transition period for registered products.
Source: ANVISA RDC 1.029/2026
🇪🇺 EU labelling of 80 fragrance allergens: final sell-through date for existing stock
What happens · what to do
Under Regulation (EU) 2023/1545, products newly placed on the market have had to comply since 31 July 2026; 31 July 2028 is the final date for selling non-compliant existing stock. Note: products manufactured before 31 July 2026 but placed on the market for the first time after that date must still comply.
What to do: Companies may consider labelling against the full EU list of 80 allergens, so that a single label serves both the UK and EU markets (listing additional allergens is not a violation). Canada's equivalent deadline is also 31 July 2028.
Source: EU Reg 2023/1545
🇪🇺 EU harmonised sorting labels become mandatory; national marks such as Triman give way
What happens · what to do
The European Commission has made clear that Member States may not retain national labels; the material codes under Decision 97/129/EC may no longer be used thereafter.
What to do: Packaging suppliers and brands need to plan mould and printing plate changes well in advance.
Source: PPWR, Article 12
🇪🇺 EU PPWR 2030: recyclability grades, PCR minimums, empty space and hotel miniatures ban
What happens · what to do
Under the Packaging and Packaging Waste Regulation (PPWR): recyclability grades A ≥95%, B ≥80% and C ≥70% (only grades A and B permitted from 2038). Minimum post-consumer recycled (PCR) content: 30% for contact-sensitive PET packaging and 10% for contact-sensitive plastic packaging made from materials other than PET (cosmetic bottles and jars fall into this category, which is less demanding than the 35% for other plastic packaging). Empty space ratio for grouped, transport and e-commerce packaging: ≤50%. Note that Annex V, item 5 (single-use cosmetic packaging in the hospitality sector) contains neither the word 'plastic' nor any ml or g threshold, so the ban applies to all materials; switching to glass, paper or aluminium does not avoid it.
What to do: Packaging suppliers and brands should move early towards mono-material and easy-to-separate designs. Dark carbon-black bottles, multi-material composites and pumps with non-separable metal springs are at high risk of falling below grade C. For the hospitality channel, options include wall-mounted refillable dispensers and large-format refill pouches, which also represent a new product opportunity.
Source: Reg (EU) 2025/40
Recent official regulatory notices
California Prop 65: 60-day notices on beauty & personal care
| Date | Chemical | Product | Alleged violators |
|---|---|---|---|
| 18 Sep | Benzophenone | Revlon Illuminance Protect + Moisturize Primer SPF 30 Sunscreen, Beauty of Joseon Day Dew Sunscreen Broad Spectrum SPF 50, Artistry Skin Nutrition… | Revlon Consumer Products LLC; Walgreen Co.; Walgreens Holding Company; Goodai Global Inc.; Sephora USA, Inc.… |
| 18 Aug | beta-Myrcene | Beta-Myrcene in Body Lotion and Shower Gel Products | Moroccanoil, Inc.; The Body Shop International Limited; The Body Shop Brand Limited; Cart.com, Inc. dba The… |
| 10 Aug | Mercury, Mercury and mercury compounds | La Tia Mana, Goree Day and Night Beauty Cream, Gold Face Fresh Beauty Cream, Jhalak Beauty Cream, Crema Facial Despigmentante, New Face Whitening… | EveryMarket Inc. |
| 17 Jul | Diethanolamine | Knight & Wilson Color Freedom Metallic Glory Permanent Hair Color | Knight & Wilson Limited; International Hair Cosmetics Limited; Knight & Wilson, Inc.; Target Corporation |
| 10 Jul | Diethanolamine | Knight & Wilson Color Freedom Metallic Glory Permanent Hair Color | Knight & Wilson Limited; International Hair Cosmetics Limited; Knight & Wilson, Inc.; Target Corporation |
| 1 Jul | Diisononyl phthalate (DINP) | Cosmetic Bags | Lilly Lashes, LLC |
| 15 Jun | Lead | ThinkKids Zinc Oxide Sunscreen SPF 50 , ThinkKids Clear Zinc 20% Sunscreen SPF 30 | Think Operations, LLC |
| 5 Jun | Diethanolamine | NatureLab Tokyo, Saisei, Stress Defense Amino Acid Shampoo | NatureLab. Co., Ltd; iHerb, LLC |
| 5 Jun | Diethanolamine | DuBarry Foundation Lotion | U.S. International Trading Corp.; Amazon.com Services LLC |
| 5 Jun | Diethanolamine | Lit Cosmetics Glitter Camo | Northwest Cosmetic Laboratories, L.L.C. |
| 5 Jun | Diethanolamine | Frank Body Everyday Nourishing Body Wash | SNDR Pty, Ltd.; Frank Body, LLC; Ulta Beauty, Inc. |
| 3 Jun | Di(2-ethylhexyl)phthalate (DEHP) | Red by Kiss Hair Coloring Kit | Ivy Enterprises, Inc dba Kiss Beauty Group; Hair and Stuff 216 |
| 29 May | Diethanolamine | Atomy Herbal Hair Shampoo | HK Kolmar USA, LLC; Atomy Co., Ltd.; Atomy America, Inc.; Amazon.com Services LLC; SOMSATANG |
| 29 May | Diethanolamine | Lit Cosmetics Glitter Camo | Elevation Labs |
| 26 May | Benzophenone | Sunscreen | Kao USA Inc.; Mario Badescu Skin Care, Inc.; Chanel, Inc.; Sol De Janeiro USA, Inc.; Elizabeth Arden, Inc.… |
EU SCCS opinions: ingredients that may be restricted next
- 30 Apr
- 26 MarPreliminarySafety of Heliotropin used in cosmetic products (CAS No. 120-57-0, EC No. 204-409-7)SCCS/1688/26
- 26 Mar
- 26 Mar
- 26 Mar
- 2 Feb
- 2 Feb
- 2 Feb
- 2 Feb
- 30 Oct 2025
- 26 Jun 2025
- 26 Jun 2025
Standing compliance rules
🇺🇸 MoCRA does not pre-empt state ingredient bans: federal rules plus strictest state limits
Under section 614 of the Federal Food, Drug, and Cosmetic Act (FD&C Act), the Modernization of Cosmetics Regulation Act (MoCRA) pre-empts state law only for six procedural requirements: registration and product listing, good manufacturing practice (GMP), records, recalls, adverse event reporting and safety substantiation. It expressly does not pre-empt state laws that prohibit or limit the amount of an ingredient. Whether an ingredient may be used therefore still depends on state law, which varies from state to state.
What to do
Companies selling into the US can consolidate state requirements into a single list of the strictest limits, for example: PFAS, none (entire class); formaldehyde releasers replaced before 2027; 1,4-dioxane ≤1 ppm across the board (New York's limit for personal care products is the strictest); lead ≤1 ppm across the board (Washington State limit); phthalates, none (entire class); mercury, triclosan, phenylenediamine, isobutylparaben, isopropylparaben and Quaternium-15, none.
🇺🇸 MoCRA facility registration must be renewed every two years
The renewal date falls two years after the date of initial registration; there is no single FDA deadline. For facilities first registered before 1 July 2024, the two-year period expired on 1 July 2026 at the latest.
What to do
Facilities should check the RENEWAL DATE field in FDA Cosmetics Direct to confirm their renewal status.
🇨🇦 Canada abolished the Foreign Site Reference Number (FSRN) system on 16 February 2026
Each Canadian importer must now independently submit complete good manufacturing practice (GMP) evidence for foreign manufacturing sites (including sites in China), with no transition period.
What to do
Overseas manufacturers should prepare a reusable GMP evidence package as a standard attachment (ISO 22716 certificate, QAR, standard operating procedure (SOP) index and stability data) so that multiple Canadian importers can each submit it.
🌍 Efficacy claims must be adapted market by market
United States: claims going beyond the wording of OTC monograph M006 (acne drug products) can make a product an unapproved new drug (in an FDA warning letter dated 16 July 2026, the formulation was compliant and the violation arose solely from promotional claims). ASEAN: wording such as 'treats', 'heals' or 'stops acne' is expressly prohibited. South Korea: leave-on acne patches may not claim to treat acne. Japan: any acne-prevention claim makes a product a quasi-drug. Canada: 'controls oil' is prohibited for acne products. Australia: descriptions of the mode of action must be limited to cleansing, moisturising, exfoliating and drying. Brazil: labelling a product for acne-prone skin moves it from Grau 1 to Grau 2.
What to do
Using one set of English marketing materials for every market risks non-compliance in several markets at once. Brands and manufacturers should build a claims system with market-specific versions. FDA explicitly treats internet content as evidence of intended use, so company websites, English pages on e-commerce and B2B platforms, and sales presentations all count.
In force / superseded
This page is for reference only; the official notices of the competent authorities prevail. Items marked 'to be verified' have not yet been checked against the original text; please consult the official source before citing them or making decisions based on them. Reviewed 22 Sep.
Show 10
🇪🇺 EU Empowering Consumers for the Green Transition Directive (ECGT) applies
What happens · what to do
Under Directive (EU) 2024/825, from 27 September 2026 and with no grace period: generic environmental claims (e.g. eco-friendly, green, biodegradable, biobased) are prohibited; carbon-neutral claims based on offsetting are prohibited outright; and sustainability labels not based on a certification scheme are prohibited. Fines can reach 4% of the trader's annual turnover in the Member State(s) concerned. Note: the separate Green Claims Directive, still at proposal stage, was reported in June 2025 to be withdrawn; this does not affect the ECGT, which applies as scheduled.
What to do: Existing stock need not all be scrapped. The common understanding on existing stock issued by the Consumer Protection Cooperation (CPC) Network in June 2026 accepts pragmatic measures such as covering or correcting claims with stickers and adding explanations at the shelf, provided companies act in good faith and correct without delay. Brands and manufacturers selling into the EU should prepare a written remediation plan before 27 September 2026 rather than relying on packaging changes alone.
Source: Directive (EU) 2024/825
🇺🇸 Minnesota PFAS initial reporting deadline
What happens · what to do
A fee of USD 800 per manufacturer applies, with reports submitted via the PRISM system of the Minnesota Pollution Control Agency (MPCA). Failure to report is a violation.
What to do: Companies that did not request an extension by 16 August 2026 were required to complete reporting by this date.
Source: MPCA PRISM · reviewed 22 Sep
🇰🇷 Korea requires a warning statement above 2.4% benzophenone-3 (oxybenzone)
What happens · what to do
Under Ministry of Food and Drug Safety (MFDS) Notice No. 2026-56. In the same amendment, leave-on hair products are exempted from 'rinse off'-type warning statements. A six-month transition period applies to packaging materials.
What to do: Check the concentration and labelling of sunscreens and colour cosmetics containing benzophenone-3.
Source: MFDS 고시 제2026-56호 · reviewed 22 Sep
🇺🇸 Minnesota PFAS reporting: deadline to request an extension
What happens · what to do
16 August 2026 was the deadline to submit an extension request for Minnesota PFAS reporting. Companies that did not request an extension had to report by 15 September 2026 via the PRISM system, at a fee of USD 800 per manufacturer. The law is regarded as the only US law that directly covers cosmetic packaging; the Minnesota Pollution Control Agency (MPCA) itself cites lipstick tubes as an example. Bottles, jars, tubes, pumps and droppers are in scope; folding cartons, leaflets and shipping cartons are not.
What to do: Packaging suppliers and manufacturers can prepare a component-level PFAS breakdown (bottle, cap, pump, dropper, etc.) and share it proactively with US brand owners to support their reporting.
Source: Minnesota Amara's Law · MPCA · reviewed 22 Sep
🇬🇧 UK bans 16 CMR substances, including TPO, from the GB market
What happens · what to do
Under regulation 2(3) of SI 2026/23, products containing these 16 carcinogenic, mutagenic or reprotoxic (CMR) substances may no longer be placed on the Great Britain (GB) market from 15 August 2026.
What to do: Brands and manufacturers should check formulations against the SI 2026/23 list without delay. TPO (trimethylbenzoyl diphenylphosphine oxide) has been fully banned in the EU since 1 September 2025.
Source: SI 2026/23 · reviewed 22 Sep
🇪🇺 EU PPWR applies in full with no grace period; German VerpackDG in force same day
What happens · what to do
The Packaging and Packaging Waste Regulation (PPWR) applies in full from 12 August 2026, with no grace period. Obligations applying from that date include: (1) the recyclability requirements of Article 6; (2) extended producer responsibility (EPR): producers must register separately in each country of sale and pay annual fees based on packaging material weight, with no exemption for micro or small enterprises, and the obligation also covers non-EU exporters selling directly to EU consumers via e-commerce; (3) PFAS limits for food-contact packaging: 25 ppb for any individual PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS including polymeric PFAS; (4) the EU declaration of conformity (DoC). In addition, the combined concentration of the four heavy metals lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg, technical documentation must be kept for five years, and economic operators must be identified on the packaging. Labelling obligations under the harmonised labelling implementing act do not apply in full until 12 August 2028. Suppliers that cannot provide Annex VII technical documentation leave their downstream partners unable to sign the DoC. From the same date, Germany requires foreign companies to appoint an authorised representative, with no exemption.
What to do: (1) Packaging suppliers and contract manufacturers should prepare a standard PPWR Annex VII compliance dossier template (six elements) so that downstream parties can sign the DoC. (2) For shipments to Germany, the Central Agency Packaging Register (ZSVR) explicitly determines the importer on the basis of Incoterms: under DAP/DDP terms the exporter is treated as the importer under German law and assumes the related obligations. Companies should review their choice of trade terms (e.g. EXW/FCA/FOB) when contracting.
Source: Reg (EU) 2025/40 · ZSVR · reviewed 22 Sep
🇮🇩 Indonesia BPJPH Regulation No. 4/2026 on halal conformity of foreign products
What happens · what to do
Complements the mandatory halal requirement taking effect on 17 October 2026: the halal conformity of foreign factories must be verified through a designated mechanism. Media reports also state that the Halal Product Assurance Agency (BPJPH) designated PT Anindya Wiraputra Konsult on 18 September 2026 to carry out overseas (pre-shipment) verification; this appears only in secondary media reports and has not been verified against the original text on the BPJPH website.
What to do: Manufacturers supplying Indonesia should confirm that the body issuing their halal certificate is on the mutual recognition agreement (MRA) list, and check with Indonesian importers whether pre-shipment overseas verification is required, allowing time and budget for it.
Source: Peraturan BPJPH No.4/2026 · reviewed 22 Sep
🇺🇸 Connecticut: mandatory PFAS labelling for 12 product categories, including cosmetics
What happens · what to do
Products must be labelled 'Contains PFAS' or 'Made with PFAS', or carry wording approved by the Department of Energy and Environmental Protection (DEEP), and must be notified to DEEP. Sales of products in these categories will be banned from 1 January 2028.
What to do: Brands and manufacturers selling into the US should carry out a full PFAS screening of their US product lines.
Source: CT PA 24-59 (SB 292) · reviewed 22 Sep
🇺🇸 Maryland Crown and Care Act adds lead to the list of banned cosmetic ingredients
What happens · what to do
Adds lead to the existing list of 24 banned ingredients, authorises enforcement by the Attorney General and increases civil penalties.
Source: MD SB 656 / HB 1533 · reviewed 22 Sep
🇺🇸 California Prop 65: vinyl acetate warning requirement takes effect
What happens · what to do
Vinyl acetate was added to the Proposition 65 list on 3 January 2025; warnings are required after a 12-month grace period. The same substance will be banned outright in California from 1 January 2027.
What to do: Review formulations of products using PVA/VA copolymer film formers (e.g. masks and patches).
Source: OEHHA Prop 65 · reviewed 22 Sep
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