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. 

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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.

Here are the key takeaways from the latest update:

• Disclosure of Fragrance Allergens in Cosmetic Labeling: The anticipated date for this proposed rule has been moved to May 2026. This is a significant delay from its previous target of January 2025.
• GMP proposed Rule: The proposed rule for cosmetic Good Manufacturing Practices has been moved from the standard agenda to the “long-term actions list.” This indicates that the Agency is unlikely to publish the Notice of Proposed Rulemaking (NPRM) within the next 12 months. The previous anticipated date was October 2025.
• Formaldehyde in Hair Straightening Products: While not a direct provision of MoCRA, the FDA’s intention to ban formaldehyde and formaldehyde-releasers in these products has a new anticipated NPRM date of December 2025. This timeline has been previously pushed back from September 2024 and March 2025.
• Test Methods for Asbestos in Talc: The Final Rule for standardized testing methods for detecting asbestos in talc-containing cosmetic products is now targeted for March 2026.

These adjustments reflect the ongoing complexities of implementing major regulatory changes. Our team at Focal Point Research will continue to monitor these developments and provide updates as they become available.

The post FDA Announces Updated Timelines for Key Cosmetic Regulations appeared first on Focal Point.

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