Regulatory activity in the cosmetics and personal care industry is accelerating across major markets. From new guidance under MoCRA in the United States to PFAS bans in France and emerging halal requirements in Indonesia, companies are navigating an increasingly complex compliance environment.
In our latest webinar, Ithos Global’s regulatory experts, joined by legal counsel, broke down what these updates mean for manufacturers, formulators, and brands. Below is a strategic overview of the most impactful developments so far this year, and what your team should be preparing for next.
United States: FDA Action Under MoCRA Is Picking Up
After a delayed rollout of some provisions, the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is now actively shaping FDA enforcement and guidance priorities.
1. Draft Guidance on Mandatory Recalls
The U.S. FDA issued draft guidance outlining how it will determine when to use its new mandatory recall authority. The document clarifies:
While recall authority may not be used frequently, the framework is now clearly defined. That alone changes risk exposure for brands.
2. Record Access & Adverse Event Documentation
The FDA also released guidance detailing its authority to access adverse event records. Companies must be prepared to provide:
If your documentation is fragmented across departments or systems, this is a red flag. The FDA’s expectations are explicit.
3. PFAS Safety Assessment
The agency’s PFAS safety review concluded that available data is insufficient to determine cosmetic safety risks. However, two important signals emerged:
This issue remains active, especially as state-level bans move forward.
4. Upcoming Allergen Disclosure Proposal
The FDA is expected to publish its proposed mandatory allergen disclosure list in May 2026. While international harmonization may be considered, the final approach remains uncertain. Companies selling globally should closely monitor alignment with EU Annex III requirements.
5. Sunscreen Active Ingredient Review
The FDA is reviewing a new sunscreen active ingredient, a category historically slow to see approvals. If approved, this could signal a shift toward more modernized sunscreen regulation in the US.
California: Ingredient Bans and Prop 65 Litigation Continue
California remains one of the most aggressive regulatory environments in the US. Here are some updates:
The C.U.R.L. Act
The C.U.R.L. Act (Combatting Unsafe Relaxers Act) will prohibit nine intentionally added ingredients in hair relaxers starting January 1, 2030. It also authorizes laboratory testing and enforcement oversight by state authorities. Reformulation timelines may seem distant, but supply chain validation should begin early.
Musk Restrictions & Safe Cosmetics Updates
California expanded its ingredient restrictions under its existing cosmetic laws, including new musk limitations and reporting updates under the Safe Cosmetics Program. Fragrance compliance documentation is becoming increasingly critical.
Proposition 65 Trends
Under California Proposition 65, litigation continues around:
Even when safe harbor levels exist, litigation risk remains high. Companies must evaluate both exposure and enforcement trends, not just regulatory thresholds.
European Union & France: Deforestation and PFAS
EU Deforestation Regulation (EUDR)
The EU Deforestation Regulation implementation timeline has been pushed back, with obligations applying first to medium and large companies. This regulation requires supply chain due diligence for certain raw materials.
Compliance will depend heavily on supplier documentation readiness.
France’s PFAS Ban
France’s ban on intentionally added PFAS in cosmetics is now in effect, with a one-year sell-through period for products already on the market. Impurity thresholds reach parts-per-billion levels.
Testing capabilities and supplier certifications are becoming essential in this environment.
United Kingdom: Divergence from the EU
The UK continues to update its cosmetic regulation independently. Recent developments include:
The children’s guidance is particularly relevant for brands marketing anti-aging or active skincare products that may appeal to younger consumers. Marketing language scrutiny is increasing.
Canada: Hotlist and Chemical Assessments
In Canada, regulators are reviewing updates to the Cosmetic Ingredient Hotlist and conducting safety assessments related to chemical use in plastics.
Health Canada continues to evaluate ingredient safety and regulatory controls. Companies selling into Canada should expect ongoing refinements to permissible ingredients and documentation requirements.
Global Developments: ANDEAN, Indonesia, China
ANDEAN Labeling
Countries in the Andean region have harmonized over-labeling allowances, providing some flexibility for imported products. This creates operational efficiencies for companies distributing regionally.
Indonesia Halal Proposals
Indonesia is considering supply chain segregation requirements for halal and non-halal products, potentially impacting raw material sourcing, production, and logistics.
If implemented, this would require significant planning for global manufacturers exporting into Indonesia.
China Ingredient Function Standardization
China is standardizing allowable ingredient functions to streamline registration and notification processes. While this increases clarity, it also demands strict alignment between formulation documentation and permitted ingredient uses.
Legal & Advertising Trends: Claims Under Scrutiny
Our legal expert highlighted several high-risk areas for cosmetic brands:
The Federal Trade Commission and competitor challenges also remain active enforcement avenues.
AI in Regulatory Compliance: Opportunity With Guardrails
Artificial intelligence tools are increasingly used to:
However, companies must protect confidential information and understand how AI integrates into SOPs and GMP expectations. AI can support compliance, but it cannot replace regulatory accountability.
What This Means for Your Business
Across jurisdictions, three themes are clear:
Regulatory compliance is no longer a reactive function. It must be embedded into formulation, supply chain management, and brand positioning from the start.
In the full webinar, our experts walk through practical examples, common mistakes we are seeing in audits and litigation, and specific steps your team can take now to reduce risk and accelerate product approvals.
If your company operates across multiple markets, this session provides strategic context you cannot afford to miss.
Watch the full webinar to access the complete regulatory breakdown and actionable guidance from our experts.
Or, if you would like to see how Ithos Global simplifies raw material qualification and global compliance management, explore our solutions or schedule a demo with our team.
