This week for ingredient & active suppliers

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

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

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

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's list includes triclocarban and nonylphenol, going further than other states.

Source: 38 MRSA c.37 · RI Consumer PFAS Ban Act

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

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

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

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

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

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

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

Brazil's National Health Surveillance Agency (ANVISA) set a 24-month transition period for registered products.

Source: ANVISA RDC 1.029/2026

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