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California Cosmetic Law Targets different substances: PFAS, Formaldehyde and More

Since the 1st of January 2025, California has been enforcing one of the most stringent state-level bans on cosmetic ingredients in the United States, the Assembly Bill No. 2762 (AB 2762), sometimes referred to as the “Toxics Free Cosmetics Act”.

Multiple substances classified as harmful to human health or the environment, are now officially prohibited in cosmetics sold in the state.

Cosmetic Ingredients Banned from 2025 in California

The regulation, led by the California Department of Public Health and enforced by the Attorney General, is already impacting manufacturers, distributors, retailers, salons and beauty professionals. Inspections are ongoing, and early reports confirm that non-compliant products are still being found, triggering immediate enforcement actions.

The 24 chemicals on the list are also present on the European Union’s Annex II of Regulation No. 1223/2009 (listing banned substances for sale in cosmetics), aligning the California Cosmetic Law with the EU standards.

The first enforcement phase targets substances sometimes used in perfumes, hair care, makeup and skin-lightening products. These include:

  • Some Phthalates such as Dibutyl Phthalate (CAS 84-74-2) and Diethylhexyl Phthalate (CAS 117-81-7) are banned as plasticizers.
  • Formaldehyde and derivatives: Formaldehyde (CAS 50-00-0), Paraformaldehyde (CAS 30525-89-4) and Methylene Glycol (CAS 463-57-0) are banned due to their known toxicity.
  • PFAS (Per- and polyfluoroalkyl substances): 13 specific compounds including PFOS, PFOA and PFNA, known as “forever chemicals”, are banned due to their persistence in the environment and potential health risks.
  • Some Parabens such as Isobutylparaben (CAS no. 4247-02-3) and Isopropylparaben (CAS no. 4191-73-5) are banned as preservatives.
  • Mercury and related compounds are banned due to its neurotoxic effects, used in some whitening creams and eye products.

 

This list was amended with Assembly Bill No. 2771, including all PFAS, by prohibiting the sale or distribution of any beauty or personal care product containing PFAS chemicals. All these ingredients must be fully removed from cosmetic formulations intended for the California market.

Amendment Made and New Substances Added

On the 8th of October 2023, it was signed Assembly Bill 496 (AB 496) into law. This legislation prohibits any cosmetic product containing twenty-six (26) specified intentionally added substances. AB 496 serves as an expansion of the existing Toxic-Free Cosmetics Act, adding substances like the following ones to the existing list:

  • Fragrance allergens, such as Butylphenyl Methylpropional, known as Lilial or Lily aldehyde (CAS no. 80-54-6).
  • Silicones, due to their environmental persistency, such as Cyclotetrasiloxane (CAS no. 556-67-2).
  • Anthraquinone (CAS no. 84-65-1).
  • Trichloroacetic Acid (CAS no. 76-03-9)
  • Vinyl acetate (CAS no. 108-05-4)
  • Boric acid (CAS nos. 10043-35-3 and 11113-50-1) and 16 different Borates and boric acid salts and esters.
  • Colouring agents, such as Basic green 1 (CAS no. 633-03-4), Basic blue 7 (CAS no. 2390-60-5) or Basic violet 4 (CAS no. 2390-59-2).

 

This new law in California, effective from the 1st of January 2027, will ban the manufacture, delivery, or sale of cosmetic products containing these 26 intentionally added ingredients. The new law is giving companies a transition time to eliminate those ingredients from their products.

Timeline for Implementation

California’s ingredient ban follows a clear regulatory roadmap to allow industry adaptation:

  • 1st of January 2025: First enforcement stage banning 13 high-priority ingredients, including the full PFAS group.
  • 1st of January 2027: Second stage under Assembly Bill 496, adding 26 more substances to the prohibited list.

This schedule requires brands to plan reformulation strategies in advance, especially if products are distributed across multiple U.S. states with different compliance dates.

What This Means for Brands Marketing in California

With the law in force, companies must act immediately. Priority actions include:

  • Auditing all product formulas to detect banned ingredients.
  • Reformulating non-compliant products, starting with high-volume or California-targeted lines.
  • Ensuring ingredient traceability and keeping documentation ready for inspections.

 

Exceptions are allowed only for trace amounts that are technically unavoidable, and companies must prove these substances were not intentionally added. Any contamination or residual presence must be documented.

Non-compliance may result in fines of up to $10,000 per violation, mandatory recalls and possible lawsuits, along with significant reputational damage in a market increasingly focused on clean beauty.

Impact on Professionals and Retailers

The ban extends beyond manufacturers. Salons, aestheticians and makeup artists must ensure they do not use non-compliant products. Retailers, both physical and online, must remove banned products from sale and dispose of remaining stock in accordance with environmental regulations.

Enforcement and Market Surveillance

Enforcement began on January 1, 2025, under the California Safe Cosmetics Program. According to official data, 173 products have been flagged in the state’s database. 12 counties are actively participating in inspections, and 18 non-compliant items were identified from about 3,000 product labels reviewed at retail.

How Cosmeservice Can Support Your Compliance in the U.S.

For companies exporting to the U.S. or selling in California, this regulatory change demands urgent action. Reformulation, ingredient verification and documentation are now essential to avoid penalties and protect brand reputation.

At Cosmeservice, we help cosmetic brands comply with both federal and California state regulations. Our services include formula assessment, banned ingredient detection, reformulation support and full compliance documentation.

Contact us at info@cosmeservice.com. Don’t risk recalls or fines, act now to keep your products compliant and market-ready.

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