This week for testing & certification bodies

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

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

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

What to do: Review formulations containing cyclosiloxanes.

Source: REACH

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

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

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

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