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.

Key Deadline:

Reporting Window: Currently Open

Submission Deadline: April 1, 2026

New Requirement: Personal Care Products

For the first time, producers of plastic containers for household cleaning and personal care products must submit annual reports on recycled content. This reporting requirement is triggered because the statutory minimum for these categories took effect in 2025. You must now report on the resin sold into Washington during the 2025 calendar year to demonstrate compliance with this new standard.

Recycled Content Targets (PCR):

Based on the compliance timeline, personal care producers should be aware of the current active requirement and the future increases mandated by law:

Current Requirement (2025): Your packaging must meet a 15% minimum PCR content standard.

Future Increase (2028): The requirement will jump to 25%.

Long-Term Goal (2031): The standard increases significantly to 50%.

Action Required:

Register: Log in to the Waste Reduction Portal.

Report: Submit your data for the 2025 calendar year, ensuring you account for the 15% PCR requirement if you are in the personal care sector.

Verify: Ensure that even if you are a de minimis producer, you complete the annual registration as required by law.

Failure to register and report by April 1, 2026, may result in non-compliance penalties. We recommend gathering your 2025 resin weight and supplier certifications immediately to meet the deadline.

The post Washington State Update: Mandatory PCR Reporting Begins for Personal Care Products appeared first on Focal Point.

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.

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.

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.