Here is a quick breakdown of what you need to know to stay compliant:

1.The ‘Flexible Approach’ for CNF Submissions

In most cases, companies are no longer required to provide the exact concentration or concentration range on the CNF for fragrance allergens. However, there is a major exception:

• If a fragrance allergen has a specific concentration-related condition listed on the Cosmetic Ingredient Hotlist, providing the exact concentration or range remains mandatory.

2. Reminder: Mandatory Labeling Requirements (April 12, 2026)

Starting April 12, 2026, fragrance allergens must be disclosed within the ingredient list on cosmetic labels if they exceed the following thresholds:

• 0.001% for leave-on products
• 0.01% for rinse-off products

This change is designed to help consumers with known allergies make informed, safe purchasing decisions.

3. Changes to the Cosmetic Notification Form (Section 5)

To accommodate these updates, Section 5 of the CNF has been revised:

• The ‘Fragrance Allergen’ checkbox has been renamed to ‘Fragrance allergen present above the disclosure threshold’.
• You must enter one fragrance allergen per ingredient line and check this box if the concentration exceeds the limits mentioned above.
• While the flexible approach allows for less details on the CNF, Health Canada still encourages manufacturers and importers to provide exact concentrations when possible.

Navigating these new regulatory thresholds can be complex. Contact us if you need assistance submitting CNFs or performing label reviews to stay compliant. 

The post Updates to the Cosmetic Notification Form appeared first on Focal Point.

What is Changing?

The update focuses on Significant New Activity (SNAc) provisions. These are risk management tools used when a substance, already on the DSL, is used in a new quantity, concentration, or circumstance that could change its impact on human health or the environment.

• SNAc requirements have been applied to 54 existing substances and modified for 161 others.
• Part 2 of the DSL (Chemicals and Polymers) is now split into Division 1 (individual substances) and Division 2 (group of substances).
• A new Schedule 1 has been added to standardize information required for SNAc Notifications (SNAN).

Why This Matters to Your Business?

The most critical takeaway is the potential for instant non-compliance. Many of these changes specifically target consumer products and cosmetics, and the triggers for reporting are much lower than previous standards.

• Low concentration triggers: Some substances now have concentration triggers as low as 0.1% or 1%.
• Low volume triggers: Compliance requirements may now kick in at just 10 kg per year. This is significantly lower than standard New Substances Notification (NSN) triggers.
• Pre-emptive reporting: Companies are required to submit a Significant New Activity Notice (SNAN) at least 90 days before the day on which the significant new activity begins. If your current operations exceed these new thresholds, you may need to act immediately.

Recommended Next Steps:

• Review your current raw materials and finished product formulations against the updated DSL list.
• Check if any of your ingredients fall under the 223 impacted substances.
• Determine if your annual use exceeds the new concentration or volume thresholds. 
• File a SNAN for any significant new activity.

If you need assistance reviewing your formulations or determining your compliance status under these new requirements, please contact us. We are here to help you navigate these changes and ensure your products remain compliant.

The post New Compliance Requirements for the Canadian Domestic Substance List (DSL) appeared first on Focal Point.

The Scope: What is regulated?

The regulation applies to nail coatings and artificial nails that contain methyl methacrylate (MMA) at concentrations greater than 1,000 parts per million (ppm).

This applies to MMA present as:

• An intentionally added ingredient.
• A residual.
• A contaminant.

Crucial Cut-off: The regulation specifically captures products manufactured on or after April 1, 2026, and sold in California.

Who Must Comply?

The onus is on domestic and foreign manufacturers selling affected products in California. If you are a Canadian manufacturer exporting to the Californian market, you fall under this scope.

Critical Compliance Timeline:

The DTSC has outlined a strict reporting schedule for 2026. Missing these dates can result in non-compliance.

April 1, 2026: The regulation becomes effective.

June 1, 2026 (The PPN Deadline): Manufacturers must submit a Priority Product Notification (PPN) to the DTSC. This notification must list all products sold in California containing MMA > 1,000 ppm.

September 28, 2026 (The Action Deadline): After submitting the PPN, manufacturers must submit one of the following via the CalSAFER portal:

• Chemical Removal Intent/Confirmation Notification
• Product Removal Intent/Confirmation Notification
• Product-Chemical Replacement Intent/Confirmation Notification
• Preliminary Alternatives Analysis Report (or alternate reporting options)

Why is this happening?

The DTSC has identified MMA exposure through normal nail product use as a potential cause of significant adverse impacts, particularly for sensitive subpopulations such as nail salon workers and pregnant people.

Next Steps for Manufacturers:

Audit Formulations: Immediately review product formulations and testing data to determine if MMA levels exceed the 1,000 ppm threshold.

Prepare for PPN: If you exceed the threshold, begin preparing your Priority Product Notification now to ensure submission before the June 1st deadline.

Decide on a Strategy: Determine whether you will reformulate (remove/replace MMA), remove the product from the California market, or conduct an Alternatives Analysis. If you would like us to review your formulations to ensure they comply with the regulations, contact us now.

The post California DTSC Finalizes MMA Regulation for Nail Products appeared first on Focal Point.

Based on mandatory industry filings, the FDA’s report offers a snapshot of how prevalent these “forever chemicals” are in the supply chain:

• The agency identified 51 different PFAS currently used across 1,744 cosmetic formulations.
• These ingredients are primarily added intentionally to enhance specific product attributes, such as water resistance, durability, and texture.
• The study concentrated on the 25 most common PFAS, which account for approximately 96% of the intentional use reported.

The Safety Verdict: Still “Inconclusive”

Perhaps the most critical takeaway is that the FDA was unable to make definitive safety determinations for the majority of the chemicals identified. The agency cited significant gaps in data and a lack of publicly available toxicological research as the primary reasons for this uncertainty.

While the report noted that five specific PFAS appear to present low safety concerns, at least one was flagged for potential safety issues.

Currently, there are no federal regulations explicitly prohibiting the intentional addition of PFAS to cosmetics in the United States. However, this report signals that scrutiny is increasing. The FDA maintains its authority to take enforcement action should specific safety risks emerge from the data.

Next Steps: Moving forward, the FDA plans to increase its monitoring and surveillance efforts. The goal is to reduce PFAS prevalence across the consumer product supply chain through expanded testing and resource allocation.

The post FDA Release: The State of PFAS in Cosmetics Under MoCRA appeared first on Focal Point.

Key proposed changes include:

• New restrictions on Basic Violet 4 and Basic Blue 7 – Prohibited in leave-on haor products; limited concentrations in other uses

• Polyaminopropyl Biguanide (PHMB) – Prohibited in spray/aerosol products; capped at 0.2% in other cosmetics

• Full bans proposed for Symphytum spp. (Comfrey) and Brucine and its salts

• Stricter limits on Furocoumarins (1 ppm in leave-on products); Imperatoin to be regulated under this broader entry

Comments must be submitted by February 17, 2026. Companies should assess product impact and prepare for compliance.

Contact us if you require regulatory support.

The post Reminder – Consultation Deadline for Hotlist Updates appeared first on Focal Point.

This proposed legislation targets the environmental impact of microplastics by regulating personal care products.

Key Compliance Dates:

• December 31, 2029 (Effective Date): By this date, no person shall manufacture or accept for sale a personal care product that contains nonbiodegradable plastic glitter.
• December 31, 2030 (Sell-Through Date): The bill allows for a one-year grace period for retail. Until this date, vendors may continue to sell existing stock of products containing the banned glitter, provided the stock was acquired and transported into the State before the December 31, 2029, deadline.

While the effective date offers a significant runway for transition, this bill signals a continued regulatory trend across the country toward the elimination of nonbiodegradable plastics in consumer goods.

Our team will continue to monitor the progress of HB 4175 to ensure future compliance.

The post Illinois Proposed Ban on Nonbiodegradable Plastic Glitter appeared first on Focal Point.

Effective January 1, 2026, non-compliant products found in Washington State will be in violation of state law, regardless of when they were purchased or manufactured.

All stakeholders with physical inventory should take the following steps:

–Audit ‘Existing Inventory’ (Acquired Before Jan. 1, 2025): If you are holding stock acquired prior to 2025 that contains restricted substances:

• Through Dec. 31, 2025: You may continue to sell these items or use them in professional services.
• Starting Jan. 1, 2026: All sales and usage must cease. You must remove these products from shelves and service areas immediately.

–Audit ‘New Inventory’ (Acquired On/After Jan. 1, 2025): Any non-compliant inventory acquired during the 2025 calendar year is already in violation. If any such stock is identified, it must be removed from sale immediately to mitigate enforcement action.

Disposition of Unsold Inventory:

The Department of Ecology has provided specific guidance for handling non-compliant goods starting January 1, 2026:

• Redistribution: Companies are permitted to move this inventory to retail locations or distribution centers outside of Washington State, provided those jurisdictions do not have similar prohibitions.
• Disposal: If redistribution is not possible, the product must be disposed of according to local waste management regulations.

Critical Warning: Do Not Donate! Companies are prohibited from donating these non-compliant cosmetic products.

If you require assistance identifying restricted chemical classes or determining compliance of specific formulations, please contact us.

The post Washington State TFCA Sell-Through Period Expires December 31 appeared first on Focal Point.

Proposed Additions (New Restrictions):

The following ingredients are being added to the Hotlist with specific usage limits:

-Basic Violet 4 (CI 42600, CAS 2390-59-2)

• Prohibited in leave-on hair products
• Restricted to a maximum of 0.4% in hair dyes and 0.2% in rinse-off hair care products

-Basic Blue 7 (CI 42595, CAS 2390-60-5)

• Prohibited in leave-on hair products
• Restricted to maximum concentrations in hair dyes (0.4%), rinse-off hair care (0.2%), nail products (0.8%), and bath products (2%).

-Polyaminopropyl Biguanide (PHMB) (CAS CAS 32289-58-0; 27083-27-8; 28757-47-3)

• Prohibited in spray or aerosol formulations due to lung risks from inhalation
• Restricted to a maximum of 0.2% in all other cosmetics

Proposed Revisions to Existing Entries:

Health Canada is proposing revisions for the following listed ingredients:

-Symphytum spp. (Comfrey)

• Prohibited: The current exception for Symphytum officinale is being removed, banning the use of this ingredient due to concerns over toxic alkaloids.

-Brucine and its salts (CAS 357-57-3; 4845-99-2)

• Prohibited: Previously restricted, this ingredient is now proposed for a total ban due to high toxicity and neurotoxic risks.

-Furocoumarins (CAS 66-97-7; 482-44-0; 642-05-7; 484-20-8; 298-81-7)

• Restricted: Intentionally adding these is not permitted.
• New Limits: Permitted only as trace contaminants in naturally occurring plant extracts, with a limit of 1 ppm (0.0001%) in all leave-on products (expanding the rule beyond just sun-tanning products).

-Imperatorin

• Removed: The specific entry for this ingredient will be removed as it will now be regulated under the broader ‘Furocoumarins’ entry.

Stakeholders are encouraged to submit comments on the changes Health Canada is proposing. The comments can be emailed or sent in writing to the Hotlist Coordinator no later than February 17, 2026. At this time, you should be evaluating your market strategy should you have products impacted by these potential updates to the Hotlist, as you will be required to comply once updates to the Hotlist are published. Should you require assistance with regulatory compliance, do not hesitate to reach out to us.

The post Health Canada Proposed Updates to the Cosmetic Ingredient Hotlist appeared first on Focal Point.

This new, user-friendly dashboard is an interactive tool that allows the public, industry, and researchers to query and download real-time data on adverse events related to cosmetic products. According to the FDA, the reports are updated daily to include the most recent submissions.

The dashboard contains data from two key sources:

• Mandatory Reports: Serious adverse event reports submitted by cosmetic companies (“responsible persons”) as required by MoCRA.
• Voluntary Reports: Reports submitted to the FDA by consumers, healthcare professionals, and others.

Impact on the Industry:

This public-facing tool marks a new era of transparency for cosmetic product safety. It provides a direct view into the safety data being collected by the agency and will be a critical resource for post-market surveillance. Companies can monitor trends related to their own products, ingredients, and entire product categories.

We encourage all industry professionals, particularly those in regulatory, quality, and safety roles, to explore this new dashboard to understand its capabilities and implications for your business.

Please contact us if you require assistance with your adverse event reporting procedures or overall MoCRA compliance strategy.

The post FDA Launches Public Dashboard for Real-Time Cosmetic Adverse Event Data 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.