Cosmetics 2026 Regulatory Roundup

This blog was originally posted on 2nd November, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY FREIDA WÜSCHNER GUBBINS, senior Regulatory Compliance Specialist and luisa toro correa, Regulatory Compliance Specialist, ADHERENT

---

Key Insight

Cosmetics businesses face changes across ingredient restrictions, labeling, packaging, claims and certification requirements in multiple markets. Understanding which requirements apply to their products, tracking compliance dates and monitoring proposals can help teams plan updates and keep market plans on track.

Contents

• Introduction
• North America: Greater Transparency and Stronger Safety Oversight
• Europe: Focus on Sustainability Measures and Substance Restrictions
• Oceania
• Latin America: Cosmetic Ingredient Restrictions Take Center Stage
• Asia: A New Era of Cosmetics Compliance, From Halal Certification to Ingredient Safety
• The Takeaway: Stay Informed, Stay Prepared
• Frequently Asked Questions

Introduction

The global cosmetics industry is navigating an increasingly demanding regulatory environment. Across major consumer markets, authorities are moving towards heightened ingredient scrutiny, aggressive sustainability benchmarks, and intensified supply-chain accountability.

In North America, consumer safety and ingredient transparency remain key priorities. Canada continues to phase in fragrance allergen labeling requirements, while cosmetics businesses in the United States must navigate both federal and state obligations. The FDA’s guidance clarifies its mandatory recall authority under MoCRA, as states move forward with PFAS restrictions, reporting, and labeling requirements.

Across Europe, regulatory scrutiny has moved well beyond foundational ingredients and health safety. The EU is setting a new precedent for lifecycle oversight: the Packaging and Packaging Waste Regulation (PPWR) introduces strict packaging traceability and design mandates, while the EmpCo Directive strictly polices environmental claims and greenwashing. For cosmetic brands, commercial viability in the EU now requires end-to-end transparency governing not just how a formula is made, but how it is packaged, and marketed. 

Meanwhile, in Latin America, Oceania and Asia, ingredient restrictions, updated safety standards and certification requirements are shaping cosmetics compliance. From Brazil’s revised ingredient lists to Australia’s requirements for retinal and Indonesia’s extended halal certification timeline, these developments highlight the importance of tracking market-specific changes and planning ahead.

In this edition of our Cosmetics Regulatory Roundup, we summarise the critical legislative shifts, ingredient bans, and enforcement policies enacted in the last few months of 2026. 

This guide aims to help cosmetics businesses identify cross-border operational exposure, plan formulation and labeling updates, and reinforce go-to-market compliance strategies heading into the coming year.

North America: Greater Transparency and Stronger Safety Oversight 

Canada: Fragrance Allergen Labeling Enters a New Phase

Canada began implementing expanded fragrance allergen labeling requirements in 2026 under SOR/2024-63, originally adopted in April 2024. As of April 12, 2026, cosmetics must disclose 24 specified fragrance allergens above established concentration thresholds. July 31, 2026, marked the end of the transition period for new products, with the expanded list of 81 allergens becoming applicable on August 1, 2026, while existing products have until August 1, 2028, to comply with the expanded list. These changes are prompting manufacturers and importers to review formulations and update ingredient labels.

United States: FDA Clarifies Its Mandatory Cosmetic Recall Powers

In October 2026, the FDA finalized guidance explaining its mandatory cosmetic recall authority under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). While the guidance does not introduce new recall powers, it clarifies when the FDA may order a recall and the procedures involved, including opportunities for companies to voluntarily recall affected products before a mandatory recall is ordered. The guidance also addresses circumstances in which a cosmetic product may pose a serious health risk, reinforcing the importance of product safety monitoring, documentation, and recall preparedness.

Beyond MoCRA: U.S. States Are Tightening Cosmetics Requirements

Meanwhile, U.S. states continue to introduce new cosmetics regulations and implement existing requirements, particularly concerning PFAS and other substances of concern. Since June 2026, several states have strengthened ingredient restrictions, reporting obligations, labeling requirements, and product safety oversight. These developments add another layer of complexity for manufacturers and importers navigating different state-specific requirements. The following highlights selected regulatory developments from June through December 2026, though regulatory activity extends beyond these states.

State	What’s happening in 2026
Connecticut	PFAS notification and labeling requirements for covered cosmetics took effect July 1, 2026.
New Mexico	Adopted 20.13.2 NMAC in 2026, establishing PFAS reporting and labeling requirements beginning in 2027 and a cosmetics prohibition beginning in January 2028.
Minnesota	Initial PFAS product reporting was due September 15, 2026, with approved extensions through December 14, 2026. The reporting framework covers qualifying products containing intentionally added PFAS, while the state’s cosmetics PFAS prohibition began in 2025.
Washington	Revised its interim compliance policy for lead impurities in cosmetics in August 2026.

Europe: Focus on Sustainability Measures and Substance Restrictions

EU: Enactment of New Packaging Requirements for Cosmetics

On August 12, 2026, the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) became applicable, requiring cosmetics manufacturers to meet new packaging traceability labelling measures, as set out in Article 15(5), and complete declarations of conformity for packaging (Article 15(2)). Further extended producer responsibility (EPR) measures will enter into force in the near future, with some already implemented across EU member states (e.g., Germany has already enacted measures for registering packaging producers).

EU: Enactment of New Measures Against Misleading Claims on Cosmetics

On September 27, 2026, Directive (EU) 2024/825 (EmpCo) on Empowering Consumers for the Green Transition became applicable, prohibiting misleading claims on cosmetic products. Claims classified as misleading under the Directive include generic environmental claims, certain carbon-offsetting claims, false claims, and advertising mandatory EU product standards as an exclusive feature.

EU: Potential New Maximum Concentration Limits for the Safe Use of Heliotropin and Acetophenone in Cosmetics

The EU frequently commissions the Scientific Committee on Consumer Safety (SCCS) to review the safety of certain substances in cosmetic products. These reviews typically serve as baseline research for formulating substance restrictions under Regulation (EC) No 1223/2009 on cosmetic products. Most recently, the SCCS adopted two opinions on the safe use of heliotropin and acetophenone in cosmetics.

Accordingly, heliotropin (CAS No. 120-57-0, EC No. 204-409-7) also known as piperonal, an aromatic compound commonly used in cosmetic products for its sweet, floral scent was considered safe when used up to a maximum concentration of 1.8% solely in fine fragrances for adults.

Meanwhile, acetophenone (CAS No. 98-86-2, EC No. 202-708-7; chemical name 1-phenylethanone) an aromatic compound valued for its sweet, floral scent and used primarily as a perfuming agent, which also occurs naturally in various plant extracts (termed “Natural Complex Substances” or NCS) was considered safe up to a maximum concentration of 100 ppm (0.01%) in cosmetic products for adults and children from 3 years of age, accounting for aggregate exposure from non-cosmetic sources.

EU: Proposals to Amend Prohibitions and Restrictions Under the Cosmetic Products Regulation

In July, two proposals were submitted to the WTO to amend the EU Cosmetic Products Regulation.

The first draft proposes a complete ban on mercury compounds by removing existing exemptions that permitted mercury-containing preservatives (thiomersal and phenylmercuric salts) in certain products. It also proposes a complete ban on newly classified CMR substances listed under Regulation (EU) 2025/1222. Finally, it proposes introducing new restriction limits for cannabidiol, butylated hydroxyanisole, butylparaben, and hydroxyapatite. If approved, the draft would also mandate the warning: “Do not use on the nappy area” for leave-on products intended for children under three years of age that contain butyl 4-hydroxybenzoate and its salts or propyl 4-hydroxybenzoate and its salts.

The second draft proposes regulating silver in cosmetic products, following a recent SCCS opinion. If approved, the amendment would ease previous restrictions on micron-sized silver powder (particle size between 100 nanometres and 1 millimetre), permitting its safe use across a wider range of products and at higher concentrations. However, a mandatory warning would be added: “Not to be used in applications that may lead to exposure of the end-user’s lungs by inhalation.”

EU: Potential Increase in Surveillance Scrutiny for Cosmetics Entering the EU Market

Beyond cosmetic specific requirements, the EU announced its intention to strengthen market surveillance for non-compliant products, including cosmetics entering the EU market, via Staff Working Document SWD(2026) 309 final. Based on this document, market surveillance authorities are expected to receive expanded regulatory tools to assess the compliance of cosmetics placed on the EU market in the near future.

UK: Joins the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

On September 1, 2026, the UK completed accession to the CPTPP. For UK based cosmetics manufacturers, this means Certificates of Free Sale (CFS) will no longer be required as a precondition to market, distribute, or sell products in other CPTPP member countries.

Ukraine: Approval of New Measures for Cosmetic Product Safety Reports

From September 1, 2026, new requirements apply to cosmetic product safety reports in Ukraine. Under the framework established by Order No. 1277, product safety reports will be aligned with the guidelines set out in EU Decision 2013/674/EU.

Oceania

Australia: End to Exemptions for the Use of Retinaldehyde in Cosmetics

On June 26, 2026, Australia published a statement classifying retinal (retinaldehyde) as a presumed human developmental toxicant: GHS Reproductive Toxicity Category 1B (H360D: May damage the unborn child). Consequently, retinal can no longer be introduced under exempted or reported categories for cosmetics, and all future introductions will require an assessment certificate.

Latin America: Cosmetic Ingredient Restrictions Take Center Stage

Brazil: Cosmetic Ingredient Lists Get a 2026 Update

In June 2026, Brazil’s ANVISA updated its lists of prohibited and restricted substances in cosmetics, personal hygiene products and perfumes through RDC Nos. 1.029/2026 and 1.030/2026. The changes support MERCOSUR regulatory harmonization and introduce revised ingredient restrictions and conditions of use. With a further revision of the restricted list still in the works, manufacturers should monitor potential reformulation needs.

Asia: A New Era of Cosmetics Compliance, From Halal Certification to Ingredient Safety

ASEAN: Cosmetic Ingredient Lists Get a Makeover

In June 2026, updated annexes to the ASEAN Cosmetic Directive introduced changes to prohibited and restricted substances, permitted colorants and preservatives. The revisions affect Annexes II, III, IV and VI, making formulation reviews particularly important for manufacturers supplying ASEAN markets. However, companies should also verify national implementation requirements and applicable transition periods.

China: A New Cosmetic Safety Standard Is on the Horizon

China published GB 7916-2026, Cosmetics, General Safety Requirements, in July 2026, replacing its 1987 cosmetics hygiene standard, which takes effect on January 1, 2028. The revised standard introduces updated requirements for cosmetic ingredients, product safety, packaging, labeling, storage and transportation, giving manufacturers time to prepare for the transition.

Indonesia: Halal Cosmetics Certification Gets a Two-Year Extension

Halal certification remains a major regulatory development for cosmetics in Asia. In October 2026, Indonesia adopted Government Regulation No. 40/2026, extending the transition period for mandatory halal certification of cosmetics from October 17, 2026, to October 17, 2028.

Thailand: New FDA Consultation Signals Potential Changes to Cosmetic Ingredient Rules

And looking ahead, on October 20, 2026, Thailand’s FDA opened a public consultation on a Regulatory Impact Analysis concerning four cosmetic ingredient amendments proposed in June 2026. The proposals address 11 prohibited substances, seven restricted ingredients, one preservative, and two sunscreen agents. While the amendments have not yet been adopted, they could introduce new formulation requirements for cosmetic manufacturers. Comments are open until November 18, 2026.

The Takeaway: Stay Informed, Stay Prepared

From ingredient restrictions to packaging, claims and certification, these developments touch multiple aspects of cosmetics compliance. For businesses operating across markets, the priority is understanding which changes affect their products and when action is needed.

Reviewing formulations, labels and supporting documentation against confirmed requirements can help identify gaps early. Meanwhile, tracking proposals and consultations gives teams time to prepare for potential changes. Turning these updates into practical steps helps businesses keep products compliant and market plans on track.

Frequently Asked Questions

What areas of cosmetics compliance are changing across global markets?

The article highlights changes to ingredient restrictions, labeling, reporting, product safety oversight, packaging, environmental claims and certification requirements. Businesses operating across markets need to identify which changes affect their products and when action is required.

Does the FDA’s October 2026 guidance introduce new mandatory cosmetic recall powers?

No. The guidance explains the FDA’s existing mandatory cosmetic recall authority under MoCRA, including when a recall may be ordered and opportunities for companies to recall affected products voluntarily.

What is the deadline for existing cosmetics to comply with Canada’s expanded fragrance allergen list?

Existing products have until August 1, 2028, to comply with the expanded list of 81 fragrance allergens. For new products, the expanded list became applicable on August 1, 2026.

When do China’s new cosmetics safety standard and Indonesia’s halal certification requirements take effect?

China’s GB 7916-2026, Cosmetics, General Safety Requirements, takes effect on January 1, 2028. Indonesia extended the transition period for mandatory halal certification of cosmetics to October 17, 2028.

Have Thailand’s proposed cosmetic ingredient amendments been adopted?

The article states that the amendments have not yet been adopted. Thailand’s FDA opened a public consultation on the Regulatory Impact Analysis on October 20, 2026, with comments open until November 18, 2026.

See Adherent in Action

Discover how agentic AI is reshaping product compliance for global enterprises.

BOOK A DEMO