What’s New in this Update?

For the first time, the list includes published recycling rates by CMC, a requirement under PRC section 42061(b).

Why It Matters:

• Defines Compliance: The list sets CalRecycle’s official determinations on which material categories meet the criteria for recyclability and compostability.
• Labeling Impact: These determinations directly influence your eligibility to use “recyclable” or “compostable” labels pursuant to PRC sections 42061(c) and (d).

The updated CMC list and guidance on categorization on the CalRecycle SB 54 Covered Material Categories can be found on the webpage. It’s time to check your product classifications against the new rates. Please contact us if you have any questions regarding this update.

The post SB 54 Update: CalRecycle Releases Updated CMC List & First-Ever Recycling Rates appeared first on Focal Point.

CARB is currently evaluating whether it is feasible for the industry to meet the upcoming 50% Volatile Organic Compound (VOC) standard using current or emerging technologies. As part of this evaluation, new reporting requirements are now in effect.

Deadline: All data for the 2025 Personal Fragrance Products Technical Assessment must be submitted to CARB by March 31, 2026.

What is Required:

Responsible Parties need to complete two main tasks:

• Submit the Data: You must use the interactive Personal Fragrance Products Reporting Tool (PFP-RT). This is a macro-enabled Excel workbook (available for both Windows and Mac) where you will list products, ingredients, and responsible parties.

Submit a Written Report: In addition to the raw data, you are required to submit a written update regarding your R&D efforts. This report should detail the work being done to meet the future 50% VOC standard.

Streamlined Process for Formulators:

To make reporting easier, CARB has changed how they handle trade secrets and third-party formulators. You do not need to contact your formulators for their data. Instead, once you submit your report (PFP-RT) listing your Product Formulators, CARB staff will contact them directly. CARB will send them a separate tool (PFP-RTF) to collect the necessary formulation data, ensuring confidentiality is maintained without you having to act as the middlemen.

This assessment is a critical step toward the January 1, 2031, regulations. By that date, non-aerosol fragrance products (with 10% or less fragrance) and aerosol products will be required to meet the strict 50% VOC limit. This assessment is CARB’s way of checking the industry’s pulse to see if the goal is achievable.

Next Steps: Download the reporting tools and review the definition of ‘Fragrance’ to ensure you are reporting the correct ingredients. If you require assistance in understanding the regulations, please contact us. 

The post CARB Launches 2025 Personal Fragrance Technical Assessment appeared first on Focal Point.

The reporting portal, which opened on September 22, requires the submission of 2023 supply data. This information will be used to establish a baseline for the source reduction requirements mandated by the SB 54 law.

Upcoming Consultation Webinars:

In addition to the reporting deadline, CAA will be hosting a series of topic-based consultation webinars starting in October 2025. These sessions are a crucial opportunity for stakeholders across the value chain to provide input and help shape the initial California EPR program plan.

How to Comply and Get more Information:

• Report your Data: Producers must submit their 2023 data though the CAA portal by November 15.
• Guidance and Resources: If you are unsure whether your company is subject to these requirements, visit CAA’s Producer Resource Center.
• Questions: For any specific questions or issues, you can contact the CAA support team directly at producer.support@circularaction.org

Please contact us if you require assistance in understanding your obligations under the California’s EPR law and preparing your data for submission.

The post Reminder: California EPR Reporting Deadline is November 15 appeared first on Focal Point.

1. Formaldehyde (CAS no. 50-00-0)
2. Isobutylparaben (CAS no. 4247-02-3)
3. Isopropylparaben (CAS no. 4191-73-5)
4. Cyclohexylamine (CAS no. 108-91-8)
5. Cyclotetrasiloxane (CAS no. 556-67-2)
6. Diethanolamine perfluorooctane sulfonate (CAS no. 70225-14-8)
7. Dibutyl phthalate (CAS no. 84-74-2)
8. Diethylhexyl phthalate (CAS no. 117-81-7)
9. Lily aldehyde (CAS no. 80-54-6)

Key Provisions of the Bill:

• The Bill requires the Department of Toxic Substances Control to adopt regulations on or before January 1, 2030
• The Department of Toxic Substances Control (DTSC) would be responsible for implementing and enforcing the new rules.
• The Bill requires DTSC to:

1. publish appropriate third-party accreditations for laboratories to test for the specified ingredients.
2. Publish a list of accepted testing methods for those ingredients.

• The Bill authorizes the department to:

1. request, and would require a manufacturer of a hair relaxer product to provide upon request, documentation, including test results, to demonstrate compliance
2. test hair relaxer products in order to support enforcement of the provisions
3. issue notices of violation and access administrative or civil penalties

Contact us today to get your formulas reviewed.

The post California introduces the “C.U.R.L. Act” to ban certain Hair Relaxers Ingredients appeared first on Focal Point.

-Ban the sale of plastic glitter in personal care products by January 1, 2030.

In his veto message, Governor Newsom explained that while he supports the goal of protecting California’s waterways from microplastics, he was not supportive of the approach this bill takes. He expressed concerns that the bill’s ban on specific ingredients, such as glitter, may incidentally result in a prohibition on biodegradable or natural alternatives.

What this means for the Industry?
This veto means the specific bans and compliance deadlines outlined in AB 823 will not become law at this time. The immediate pressure to reformulate away from plastic glitter based on this bill has been lifted. However, this topic remains a high priority issue for legislators and consumers. Our team will continue to monitor any furfure legislative efforts to regulate microplastics in cosmetics.

The post California Governor Vetoes Bill to Ban Plastic Glitter (AB 823) appeared first on Focal Point.

The establishment of these NSRLs provides a clear ‘safe harbor’ threshold for businesses. If exposure from a product is below these levels, a Prop 65 warning for cancer risk is not required.

The New NSRLs:

The OEHHA has set two distinct daily exposure limits based on particle size:

• 440 micrograms per day for airborne, unbound titanium dioxide particles with diameters of 10 micrometers or less
• 44 micrograms per day for airborne, unbound titanium dioxide particles with diameters of 08. micrometers or less

Please contact us if you would like assistance with formula reviews or exposure assessments to ensure compliance with Prop 65.

The post California Finalizes Prop 65 Safe Harbor Levels for Titanium Dioxide appeared first on Focal Point.

The proposed NSRLs are 54 µg/day for 1-bromopropane and 6.4 µg/day for dermal exposures to diethanolamine.

Why this Matters for the Cosmetic Industry

This is a critical development for any brand selling products in California. Diethanolamine has been a frequent target of Prop 65 enforcement and litigation often due to its presence as a low-level contaminant or as an impurity in the widely used ingredient triethanolamine (TEA). Products ranging from lotions and sunscreens to shampoos and color cosmetics have been subject to notice of violation.

The establishment of a formal NSRL provides much needed clarity and a legal safe harbor. If a company can demonstrate through exposure assessments that a consumer’s dermal exposure to diethanolamine from their products is below this 6.4µg/day threshold, they will be exempt from Prop 65’s warning requirements for that chemical.

The proposal is currently open for public comment. OEHHA is accepting electronic comments until the deadline of November 7, 2025. Industry stakeholders are encouraged to review the proposed regulatory text and provide feedback.

Please contact us if you would like assistance with formula reviews or exposure assessments to ensure compliance with Prop 65.

The post California Proposed Prop 65 “Safe Harbor” Level for Diethanolamine appeared first on Focal Point.

Companies with products on the market in California should take note, as the new rules will come into effect on January 1, 2027.

Here is a breakdown of the fragrance ingredients impacted by the bill:

Prohibited Ingredients

Beginning in 2027, the following ingredients will be completely banned from use in cosmetic products sold in California:

• musk ambrette (CAS no. 83-66-9)
• musk tibetene (CAS no.145-39-1)
• musk moskene (CAS no. 116-66-5)
• musk xylene (CAS no. 81-15-2)

Restricted Ingredient

The bill also places strict concentration limits on musk ketones, which will vary by product type:

• musk ketone (CAS no. 81-14-1)
• maximum 1.4% in fine fragrance products
• maximum 0.56% in eau de toilette
• 0% in oral products
• 0.042% in all other products

Next Steps for the Industry: With a compliance deadline of January 1, 2027, manufacturers and formulators are advised to begin reviewing their product portfolios now. This will allow ample to identify any affected products and undertake necessary reformulations to ensure continued compliance in the California market.

The post State Update: California’s MUSK Reduction Act to Ban and Restrict Key Fragrance Ingredients appeared first on Focal Point.

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According to the Office of Environmental Health Hazard Assessment (OEHHA), Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, mandates that businesses provide a clear warning before intentionally exposing individuals to any chemical listed as a carcinogen or reproductive toxicant.

During the drafting of a regulatory proposal by OEHHA, the industry pushed back, requesting a preliminary injunction to halt enforcement due to the lack of a defined ‘safe harbor’ level for titanium dioxide. This absence created uncertainty about when a warning would be necessary.

In response, OEHHA proposed a ‘No Significant Risk Level’ (NSRL) for titanium dioxide (airborne, unbound particles of respirable size). The suggested NSRL would apply if the daily average exposure does not exceed:

1. 440 micrograms (µg) for airborne, unbound particles with diameters of 10 micrometers (µm) or less, and
2. 44 micrograms (µg) for airborne, unbound particles with diameters of 0.8 micrometers (µm) or less.

Both parts of the NSRL must be met before it applies.

The notice initiated a 45-day public comment period that was scheduled to close on June 24, 2024. OEHHA has extended the public comment period on amending the California Code of Regulations to incorporate the proposed NSRL for TiO2. Comments on the proposed regulation will now be accepted until July 1, 2024.

OEHHA strongly recommends that comments be submitted electronically through their website at https://oehha.ca.gov/comments.

The post Extension of Comment Period for Proposed Amendment to Section 25705(b) on Safe Exposure Levels for Titanium Dioxide Under Proposition 65 appeared first on Focal Point.