Passed in May 2023, this legislation mandates that businesses must report intentionally added per- and polyfluoroalkyl substances (PFAS) in products sold within Minnesota and pay an associated fee.

​Products manufactured prior to July 1, 2023, are strictly excluded from these reporting requirements.

Companies should be aware that after a formal review period, all submitted data will become publicly accessible, with the exception of verified trade secrets.

​Critical 2026 Reporting Deadlines:

​Because the initial reporting deadline is approaching rapidly, manufacturers are highly encouraged to begin their data entry and submit any necessary technical support requests immediately. Please ensure your compliance teams track the following key dates:

• ​September 15, 2026: Initial PFAS reports are officially due.
• ​November 14, 2026: For manufacturers who previously secured a due date extension, requests for waivers must be postmarked or mailed by this date.
• ​December 14, 2026: Initial reports are due for manufacturers operating under an approved extension.
• ​February 1 (Annually): Moving forward, subsequent annual updates will be required each year on this date.

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

The post Upcoming Deadlines for Minnesota’s PFAS Reporting appeared first on Focal Point.

​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 RI HB 7734:

• The law strictly prohibits the sale of covered products (including cosmetics) that contain intentionally added PFAS.
• ​This prohibition will officially take effect beginning January 1, 2027.

​Considering the upcoming deadline, contact us today to review your product formulations to ensure full compliance before enforcement begins.

The post Rhode Island Enacts PFAS Ban on Covered Products 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.

DTSC’s decision is driven by environmental and health safety evaluations regarding this class of chemicals. The department has determined that PPD derivatives are expected to exhibit specific hazard traits, primarily dermatotoxicity and wildlife survival impairment.

​Regulators are concerned that these derivatives may cause or contribute to adverse dermatological impacts (such as skin sensitization) as well as severe adverse aquatic impacts (such as death).

​What This Means for Your Business:

​It is important for manufacturers and formulators to understand the immediate impact of this update. Adding a chemical to the Candidate Chemicals List does not create any new regulatory obligations. However, this listing serves as a strong indicator that PPD derivatives are under scrutiny and may be targeted for future evaluation or product prioritization by the DTSC.

​If you have any questions regarding this update or would like to get your formulas reviewed, our team is here to help. Contact us today.

The post California DTSC Updates Candidate Chemicals List to Include PPD Derivatives 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.

Medical devices are subject to exemptions where PFAS are essential to the device and their use do not pose serious harm to users. Manufacturers should assess whether their products meet the applicable exemption criteria.

A new PFAS labeling requirement will also take effect January 1, 2027. Products containing intentionally added PFAS sold or distributed in New Mexico will be required to display a standardized PFAS symbol. The Environmental Improvement Board finalized the implementing rules in March 2026, with the Final Rule published in the New Mexico Register on May 5, 2026.

To ensure your compliance with this new requirement, please contact us.

The post New Mexico PFAS Protection Act: Cosmetics Restrictions Begin in 2028 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.

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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.

Upcoming Formaldehyde Releaser Restrictions:

On August 28, 2025, Washington became the first state to enact a comprehensive ban on formaldehyde-releasing chemicals in cosmetics. These new restrictions specifically target 25 intentionally added formaldehyde releasers, as well as their CAS RN aliases.

By defining an “intentionally added” chemical as one that serves a specific intended function within a product or ingredient, the state restricts any chemical that releases formaldehyde when the formaldehyde itself serves a functional purpose.

This mandate impacts cosmetics manufacturers, distributors, retailers, and cosmetology businesses operating within Washington state. The rules apply universally to all cosmetic products, whether they are used in professional services, sold online, or purchased in physical retail stores.

Important Upcoming Deadlines:

• January 1, 2027: The restrictions on formaldehyde releasers will officially go into effect.
• December 31, 2027: In-state retailers are required to completely sell through their existing stock by this final date.

A Reminder on Formaldehyde and Methylene Glycol:

As a quick reminder, restrictions targeting formaldehyde and methylene glycol have already been in effect since January 1, 2025. The allowed sell-through period for these specific chemicals concluded on December 31, 2025.

As a result, products containing formaldehyde or methylene glycol, which are frequently found in hair straightening solutions like keratin treatments, can no longer legally be kept on store shelves or used in salons across Washington. If your business manufactures, distributes, or sells cosmetics containing these ingredients, you must halt operations involving those items immediately and review state compliance guidance.

How to Prepare for the 2027 Restrictions:

To ensure readiness for the upcoming changes, businesses should take the following proactive steps:

• Carefully review all product labels and verify ingredients against the state’s restricted chemicals list.
• Conduct thorough research into product ingredients, as formaldehyde releasers used as preservatives may not always be explicitly listed on product packaging.
• Consult the updated TFCA Guide for strategies to determine if your products contain hidden formaldehyde releasers.

Updated TFCA Guide Now Available:

Because any business manufacturing, distributing, selling, or using cosmetics in Washington must comply with the TFCA, the state has recently updated its official guide for industry and sellers.

The revised guide now fully incorporates the new formaldehyde releaser restrictions. It is a critical resource that explains exactly which chemicals are restricted and when the deadlines hit. The guide is designed specifically to help you evaluate your supply chain, identify restricted chemicals in your inventory, and understand the necessary next steps to achieve full compliance. If you need help understanding these new requirements, contact us today.

The post Spring 2026 Update: Washington’s Toxic-Free Cosmetics Act (TFCA) appeared first on Focal Point.