​Key Provisions of Virginia HB 122:

• ​The law strictly prohibits the use of certain intentionally used ingredients.
• ​The bill has successfully passed and its status is officially updated to enacted.

​To review your product formulations and ensure continuous compliance with emerging state-level legislation, please contact us.

The post Virginia Enacts Ingredient Restrictions (HB 122) appeared first on Focal Point.

​Key Provisions of the Enacted Bills:

​This legislation introduces strict regulatory requirements and robust enforcement mechanisms for the personal care industry:

• ​The enacted bills prohibit the manufacture, sale, or distribution of cosmetic and hair care products in Maryland that intentionally contain lead and certain other harmful chemicals.

• ​The Maryland Department of Health is now authorized to actively investigate complaints and enforce compliance with the new restrictions.

• ​Violations of the law are considered unfair trade practices. Businesses found in violation may face significant civil damages, which can include treble and punitive damages in cases of willful non-compliance.

​These new laws underscore the growing trend of state-level scrutiny regarding cosmetic ingredients, emphasizing the immediate need for rigorous formula and supply chain reviews to ensure compliance in the Maryland market.

​To get your formulas reviewed and to ensure compliance, contact us today.

The post Maryland Enacts Ingredient Restrictions for Cosmetics and Hair Care appeared first on Focal Point.

The proposal would also clarify that cosmetics sold directly to consumers are not subject to Louisiana’s facility permitting and inspection requirements. Businesses would still need to comply with applicable federal requirements under the FD&C Act and MoCRA, as well as state and local tax requirements.

If enacted, the changes could reduce regulatory and administrative requirements for small, home-based cosmetic businesses in Louisiana, while maintaining federal compliance obligations. Companies should monitor the legislation, particularly the $100,000 sakes threshold and product exclusions, when assessing eligibility for the proposed exemption.

For more such updates, contact us.

The post Louisiana moves to ease cosmetic requirements for cottage businesses appeared first on Focal Point.

The legislation is not currently expected to advance in Congress, but its introduction reflects continued federal scrutiny of PFAS in cosmetics. Companies should continue monitoring federal and state PFAS developments and review formulations, raw materials and packaging for intentionally added PFAS.

For further updates, do reach out to us.

The post US Federal: No PFAS in Cosmetics Act Introduced appeared first on Focal Point.

Beginning July 1, 2028, cosmetic products containing specified intentionally added substances will be prohibited from being manufactured, sold, delivered, held, or offered for sale in Illinois. The substances include Dibutyl phthalate (DBP), Diethylhexyl phthalate (DEHP), formaldehyde, paraformaldehyde, methylene glycol, quaternium-15, mercury, isobutylparaben, m-phenylenediamine and its salts, o-phenylenediamine and its salts, and specified PFAS and their salts, including PFOS, PFOA and PFNA.

The Act is intended to align Illinois restrictions with corresponding prohibitions under the European Union Cosmetics Regulations (EC) No. 1223/2009, as amended. Importantly, the law provides an exemption where a prohibited ingredient is present only as a technically unavoidable trace resulting from impurities in raw materials, the manufacturing process, storage, or packaging, provided the product was manufactured through a process intended to comply with the Act.

Cosmetic manufacturers and suppliers should begin reviewing formulations, raw material specifications, and supply chains against the substances listed under HB 3409 and assess reformulation needs well ahead of the July 1,2028 compliance date. To ensure your compliance with this new requirement, please contact us.

The post Illinois enacts restrictions on certain chemicals in cosmetics appeared first on Focal Point.

​SB 54, California’s landmark extended producer responsibility (EPR) and plastic pollution prevention law is facing growing pushback from industry stakeholders as new economic analyses and operational assessments reveal critical flaws in the program’s current framework.

​What Triggered the Push for a Pause?

• ​Independent assessments based on CalRecycle’s July 2025 Standardized Regulatory Impact Assessment (SRIA) and a February 2026 third-party Needs Assessment project total 5-year compliance costs to reach $78 billion- roughly 3.5 times higher than initial projections.
• ​Industry faces $2 billion in fees during the first year alone, with initial invoices rolling out and larger fees scheduled for January. Over five years, direct program fees are projected to climb to $17.2 billion (rising from $2B in Year 1 to $5B in Year 5).

The designated Producer Responsibility Organization (PRO), Circular Action Alliance (CAA), has formally indicated that it cannot meet SB 54’s statutory targets as currently written in its Program Plan, raising concerns that massive fees will be collected without achieving the intended recycling outcomes.

​Key Takeaways for Businesses and Regulated Producers:

• ​The coalition is not advocating for the elimination of SB 54, but rather a temporary legislative freeze. Because the targets and compliance timelines are hardcoded into statute, only the California Legislature can adjust the framework.
• ​Objective for 2027–2028: The requested pause aims to halt impending fee hikes while lawmakers and industry collaborate during the 2027–2028 legislative session to restructure the program into a workable, cost-effective model.

​​

If you have any questions regarding how this update may affect your business, do reach out to us today.

The post Industry Coalition Calls for Immediate Pause on California SB 54 Packaging Mandates appeared first on Focal Point.

The recent revisions intend to broaden the list’s applicability, increase labelling flexibility, and reduce the overall administrative burden for companies.

​Key Changes in the August 2026 Update:

• ​Transition to a Non-Exhaustive List: For NHPs and NPDs covered by List D (low-risk products used on the skin or in the mouth), the terms provided in Health Canada’s table are now treated as examples rather than a strict, exhaustive list. Companies may use other equivalent wording provided it conveys the exact same meaning and meets Health Canada’s requirements.

• ​Flexibility in Product Claims: The revised guidelines now allow the application of interchangeable terminology directly to NHP claims and the uses or indications for List D NPDs.

• ​Grammatical Adaptability: Companies have additional flexibility with grammar, such as using different verb tenses interchangeably (e.g., “ask” versus “asking”). This is permitted as long as the fundamental meaning of the sentence is not altered.

​Important Limitations to Keep in Mind:

• ​While the updated guidance provides more freedom to create consumer-friendly labels, it is not a blanket authorization to rewrite product information.
• ​Interchangeable terms must always convey the identical meaning of the authorized term and cannot be false or misleading.
• ​Some term substitutions are unidirectional. For example, the term “avoid” can be substituted with the stricter “do not,” but “do not” cannot be weakened to “avoid”.

​This regulatory update presents a valuable opportunity for NHP and NPD companies to review their existing/upcoming labels and replace overly technical jargon with more accessible language for consumers.

​If you need assistance with reviewing your label claims, please reach out to us.

The post Health Canada’s Update on Interchangeable Terms for NHPs and NPDs appeared first on Focal Point.

​While the published regulations formally introduced two new substance categories, i.e., Dechlorane Plus (DP) and decabromodiphenyl ethane (DBDPE), an update to ECCC’s Substances Search Tool reveals an increase in the listed substances, jumping from 209 CAS RNs under the 2012 Regulations to 3,218 CAS RN entries with the 2025 Regulations.

The addition of over 3,000 CAS RNs does not reflect new regulatory amendments, but rather individual chemicals that fall under broad structural definitions already regulated, particularly per- and polyfluoroalkyl substances (PFAS) such as PFOA, PFOS, and LC-PFCA precursors.

​The List is Non-Exhaustive: ECCC emphasizes that its database is a compliance guide, not an all-inclusive list. If a substance meets the structural definition outlined in the regulations, it is prohibited or restricted regardless of whether its CAS RN is explicitly cataloged.

​A screening by industry regulatory teams identified 13 cosmetic-relevant CAS RNs linked to International Nomenclature of Cosmetic Ingredients (INCI) names: including ingredients like Perfluorononyl Dimethicone, Perfluorooctylethyl Triethoxysilane, and certain fluorinated phosphates.

​Recommended Next Steps for Manufacturers and Brand Owners:

• Review all cosmetic ingredients and formulations against relevant substance groups and definitions.
• Request comprehensive ingredient disclosures and Certificates of Analysis (CoA) from the suppliers.
• Review relevant packaging, components and other materials associated with cosmetic products, as these may also be implicated.

Ensuring proactive compliance with evolving Canadian environmental standards is essential to preventing supply chain interruptions, product recalls, or import holds.

​If you have any questions regarding how this update may affect your business, do reach out to us today.

The post Canada Expands Substances Under Toxic Substances Regulations (2025) appeared first on Focal Point.

Inspectors reviewed 96 cosmetic products, including 41 imported products, through both online and in-person inspections. The findings underscore the importance of regulatory compliance:

• 35 products were found to be compliant
• 31 products required companies to commit to corrective actions
• 30 products were subject to stop distribution measures due to non-compliance

The most common deficiencies involved labeling non-compliance, while several products also failed to meet Cosmetic Notification requirements. These findings reinforce that Health Canada continues to prioritize accurate product labeling and ingredient disclosure, particularly for ingredients with specific conditions of use such as eucalyptus oil.

For cosmetic manufacturers, importers, and brand owners, this report serves as an important reminder that compliance extends beyond formulation. Companies should ensure that products meet the requirements of the Food and Drugs Act, the Cosmetic Regulations, and the Cosmetic Ingredient Hotlist, including:

• Accurate bilingual labeling and mandatory label information
• Timely submission of Cosmetic Notifications
• Compliance with ingredient-specific restrictions and cautionary statements
• Regular reviews of imported products to ensure Canadian regulatory requirements are met before market entry

Although HC notes that Compliance Verification Projects target products considered more likely to be non-compliant and therefore do not represent the overall Canadian marketplace, the results demonstrate that deficiencies can result in significant business impact, including stop-sale and stop-distribution actions. For companies operating in Canada’s cosmetics market, proactive label reviews and regulatory audits remain one of the most effective ways to reduce compliance risk.

Give us a call to ensure your product’s compliance.

The post Key Takeaways from Health Canada’s Cosmetic Compliance Verification Project appeared first on Focal Point.

Key Changes in the 2025 Regulations:

The 2025 regulatory framework completely repeals and replaces the older 2012 regulations. Key updates include:

• Stricter restrictions have been placed on the manufacture, use, sale, and import of PFOS, PFOA, LC-PFCAs, HBCD, and PBDEs.
• New controls have been introduced for Dechlorane Plus (DP) and decabromodiphenyl ethane (DBDPE).
• To support businesses in transitioning to alternative ingredients, there are temporary exemptions and permit options available.
• New laboratory reporting requirements apply to DP and DBDPE, which must be submitted using Environment and Climate Change Canada’s (ECCC) Regulatory Services Platform.

Updates to the Export Control List:

Changes to the Export Control List were launched at the same time.

• Export controls have been added for PFOA, LC-PFCAs, HBCD, PBDEs, and ferbam.
• These updates help Canada fulfill its international commitments under the Rotterdam Convention regarding the trade of hazardous chemicals and pesticides.
• While Dechlorane Plus (DP) has also been added to the Export Control List, this specific listing will not be enforced until December 31, 2030.

Next Steps for Businesses:

If your company manufactures, imports, or exports any of these affected substances, you should carefully review the new requirements to determine if you have any permit or reporting obligations. Please feel free to reach out to us if you have any questions regarding this update.

The post New Toxic Substances and Export Control Regulations Now in Force appeared first on Focal Point.