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Wrapping Up 2025

Cosmetic Regulations 2025: A Year of Transformation for Beauty Brands

By Carmen M. Lerga BSc (Hon) MRSC, MSCS, MIFSCC, for Olalla Consulting |

The year 2025 has been nothing short of transformative for the global beauty and personal care industry. Regulatory authorities across the EU, UK, USA, and Canada have introduced sweeping changes that will redefine how brands formulate, package, and market their products. For many, this marks the most significant regulatory overhaul since the early 2010s, with compliance deadlines stretching into 2026 and beyond.

For brand owners, formulators, and compliance teams, the message is clear: adapt now or risk being left behind.

European Union: Sustainability and Transparency Take Centre Stage

The EU has led the charge with three landmark regulatory updates:

  • European Deforestation Regulation (EUDR): Effective 30 December 2025 for large and medium enterprises, and 30 June 2026 for SMEs, this law requires brands using palm oil, cocoa, soy, or rubber to prove their supply chains are deforestation-free. Companies must trace raw materials to the exact plot of land and file digital due-diligence statements. Non-compliance could mean fines of up to 4% of annual EU turnover.
  • Fragrance Allergen Expansion (Regulation 2023/1545): The EU has expanded mandatory allergen labelling from 26 to 82 substances, with compliance deadlines of 31 July 2026 for new products and 31 July 2028 for existing stock. This will require relabelling, reformulation, and updates to Product Information Files (PIFs).
  • Extended Producer Responsibility (EPR): From August 2026, eco-modulated fees will penalize brands using hard-to-recycle packaging. Companies must track packaging weights, register with Producer Responsibility Organisations (PROs), and redesign packaging for recyclability.

United Kingdom: Packaging Accountability

The UK is aligning closely with EU packaging reforms. Under its Extended Producer Responsibility (EPR) scheme, brands with turnover above £1 million or placing more than 25 tonnes of packaging annually must register and submit data by 1 April 2025. Fees will begin in 2026.

This shift transfers recycling costs from local authorities to producers, incentivising sustainable packaging design. For UK-based beauty brands, early data tracking is essential to avoid penalties.

United States: MoCRA and State-Level Ingredient Bans

The Modernization of Cosmetics Regulation Act (MoCRA) continues to reshape the U.S. market. By 29 December 2025, the FDA will finalise rules covering:

  • Good Manufacturing Practice (GMP) standards
  • Fragrance allergen labelling
  • PFAS safety reporting
  • Standardised talc-asbestos testing

GMP audits will begin in 2026, requiring FDA-compliant records and procedures.

Meanwhile, states are moving aggressively on ingredient bans:

  • California, Colorado, Minnesota banned PFAS from 1 January 2025.
  • Maine and Vermont will follow in 2026.
  • California, Maryland, Washington enacted “Toxic-Free Cosmetics” laws banning over 24 chemicals, including formaldehyde, parabens, and phthalates.

Packaging EPR deadlines also loom, with states like Oregon, Colorado, and California requiring registration and data submissions throughout 2025, ahead of fee implementation in 2026.

Canada: Hotlist Updates and Language Rules

Canada has tightened its Cosmetic Ingredient Hotlist, banning thioglycolic acid esters and restricting retinol, retinal, peroxides, and cresols as of 28 February 2025.

Other key updates include:

  • Allergen Labelling: Phased implementation begins 12 April 2026, with full compliance required by 1 August 2028, mirroring EU thresholds.
  • Québec’s Bill 96: From 1 June 2025, French text must be as prominent as English on labels, and English trademarks must be translated unless officially registered.
  • Federal Labelling Rule: Since 31 October 2024, all cosmetics must display a bilingual consumer contact point.

Compliance Deadlines at a Glance

Country

Regulation

Deadline

EU

EUDR

Dec 2025 (Large/Med), Jun 2026 (SMEs)

EU

Fragrance Allergen Labelling

Jul 2026 (new), Jul 2028 (existing)

UK

EPR

Apr 2025 data, 2026 fees

USA

MoCRA

Dec 2025

USA

PFAS/Toxic Bans

2025–2026

USA

Packaging EPR

2025 data → 2026 fees

Canada

Hotlist Update

Feb 2025

Canada

Allergen Labelling

Apr 2026 → Aug 2028

Canada

Language Labelling

Jun 2025

Canada

Contact Info Rule

Oct 2024

What Brands Should Be Doing Now

  • Audit ingredients for compliance with EUDR and MoCRA.
  • Map packaging data and redesign for recyclability.
  • Reformulate to remove PFAS and other banned substances.
  • Update labels for allergens and bilingual requirements.
  • Register with PROs in each region to meet EPR obligations.

Final Thoughts

2025 has been a watershed year for cosmetic regulation. The convergence of sustainability, safety, and transparency is reshaping the industry’s future. For beauty brands, compliance is no longer just a legal requirement, it’s a competitive advantage.

Those who act early, auditing supply chains, reformulating responsibly, and embracing sustainable packaging, will not only avoid penalties but also position themselves as leaders in a market increasingly defined by trust and accountability.

The next 18 months will be critical. Brands that invest in compliance now will be the ones thriving in 2026 and beyond.

 

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