The regulatory environment for cosmetic and personal care brands is undergoing its most significant transformation in decades. Static checklists are no longer sufficient; today’s compliance function is fast-moving, globally connected, and under intense visibility. Chemical restrictions, evolving safety expectations, and increasing litigation pressure are reshaping how brands operate across every major market.
As discussed in our Q3 Quarterly Regulatory Roundup webinar, regulatory teams are confronting accelerating state-level ingredient bans, evolving safety standards, new reporting obligations, and tightening international frameworks, while managing heightened public and legal scrutiny.
We’ve created a streamlined recap of the key regulatory shifts covered during the session, along with the strategic actions brands should prioritize now. To dive deeper, you can watch the full webinar recording anytime.
PFAS Regulations and the Chemical Policy Shift
Across the U.S., transparency demands continue to rise, and PFAS restrictions are now a defining regulatory pressure point. States including Minnesota, Colorado, Maine, and Washington are shifting from proposals to enforceable bans, with many provisions taking effect in 2025.
A key new reality: Regulators may increasingly require laboratory testing to validate PFAS compliance, rather than relying solely on supplier attestations. This places the burden directly on brands and their safety teams.
What This Means for Brands
- Confirm PFAS compliance using testing where required.
- Review formulations proactively to eliminate at-risk ingredients.
- Strengthen documentation so you can defend safety decisions if questioned by regulators.
Global Regulatory Shifts: A New Era of International Complexity
While U.S. regulations evolve, global markets are also undergoing major structural changes, many aligning more closely with EU-style frameworks while maintaining unique local requirements.
India’s EU Alignment
India is introducing EU-like Annexes for prohibited and restricted substances, along with stricter post-market surveillance. New recordkeeping expectations require brands to be fully inspection-ready throughout the entire product lifecycle, not just compliant at import.
CNF Health Canada: Increased Accuracy and Visibility
Canada’s updated CNF Health Canada process puts greater emphasis on accurate labeling, allergen disclosures, and warnings. The new system collects additional information, making discrepancies more visible to regulators.
ASEAN Markets (Indonesia & Vietnam)
Although both operate within the ASEAN Cosmetic Directive, each country applies and enforces requirements differently.
- Indonesia is expanding rules for halal labeling and packaging format requirements.
- Vietnam continues to introduce additional local clarifications that brands must follow to avoid delays.
Strategic Takeaway
Effective compliance now requires understanding how each country enforces its rules in practice. Ithos supports this by delivering client-specific quarterly regulatory reports that summarize which global changes affect your products, allowing you to anticipate impacts and adjust formulations, labeling, and documentation proactively.
EU Cosmetic Compliance: Ingredient Reviews and Operational Challenges
The EU and UK continue to influence global chemical policy, and their ongoing ingredient assessments create significant operational implications for brands.
Microplastics in Cosmetics Ban
The EU ban on microplastics in cosmetics, beginning with rinse-off products in 2027, requires early reformulation planning and robust evidence to support compliance.
Titanium Dioxide Assessments
The SCCS continues to review Titanium Dioxide safety in oral care, driven by new data. SCCS opinions eventually become regulations about 98% of the time, making early monitoring crucial for long-term planning.
Operational Takeaway
- Do not rely solely on supplier data.
- Maintain updated, comprehensive ingredient safety documentation.
- Track SCCS preliminary opinions to gain a potential two-year head start on reformulation.
Legal Landscape: Claims, Litigation, and FDA Cosmetic Product Listing
The legal risks associated with cosmetic regulation are rising, driven not only by regulatory agencies but also by plaintiffs’ attorneys who monitor public filings, claims, and ingredient disclosures.
Marketing Claims Under Legal Scrutiny
Class actions increasingly target vague or unqualified terms such as clean, natural, or vegan.
The highest-risk situations occur when a brand’s public “made without” lists do not align with actual formulations or supplier data.
FDA Cosmetic Product Listing & Safety Documentation
With more public-facing documentation, including FDA cosmetic product listing, any inconsistency between safety substantiation, claims, ingredient disclosures, and marketing language increases litigation exposure.
What This Means for Brands
- Ensure claims align with formulations and all supporting documentation.
- Review publicly available ingredient commitments for accuracy.
- Treat safety assessments and product listings as documents likely to be reviewed in litigation.
Proactive Compliance: Powered by Ithos Global
Regulatory teams sit at the center of product integrity, brand trust, and global market access. But with rapidly changing regulations and increased scrutiny, manual processes are no longer sustainable.
These capabilities are core strengths of Ithos:
- Data Integrity: IIN centralizes and maintains up-to-date safety assessments, claims language, and ingredient documentation so everything remains aligned and defensible.
- Horizon Scanning: With quarterly, product-specific regulatory reports, IIN helps brands anticipate international changes.
- Integrated Workflows: The IIN platform embeds global compliance requirements directly into product development, reducing errors and operational risk.
In a world defined by radical transparency and rapid regulatory change, proactive compliance, supported by the right tools and intelligence, is your competitive advantage.
For more information on these latest updates, watch our on-demand webinar: Q3 Quarterly Regulatory Roundup.
