The Proliferation of State-level Regulation of PFAS in Consumer… - Kelley Drye & Warren LLP
State-level PFAS regulations are proliferating, with new bans and disclosure requirements for cosmetics and personal care products. This creates a patchwork of compliance obligations beyond federal MoCRA rules.
Aforeworn detected this change in the Cosmetics & Personal-Care (MoCRA) space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Indie beauty brands, contract manufacturers, private-label makers, importers/distributors should confirm how it applies to their specific situation before acting. There is a time constraint attached: Varies by state; some laws effective as early as 2025. Immediate review recommended.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Cosmetics & Personal-Care (MoCRA) continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
Multiple states (e.g., California, New York, Maine, Washington) are enacting laws banning or requiring disclosure of PFAS in cosmetics. These laws have varying effective dates and thresholds.
Who it affects
Indie beauty brands, contract manufacturers, private-label makers, importers/distributors
What you must do
Review product formulations for intentionally added PFAS and assess compliance with each state's requirements. Update labeling and registrations as needed.
Deadline
Varies by state; some laws effective as early as 2025. Immediate review recommended.
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- New Jersey bans some products with toxic PFAS chemicals. Here’s what to know - WHYY
- Implementing MoCRA: FDA Releases New Draft Guidances on Insanitary Conditions for Tattoo Ink and Cosmetic Product Registration & Listing - Food and Drug Law Institute (FDLI)
- France bans PFAS in cosmetics – COSlaw.eu - Guiding through EU Cosmetics Regulations - COSlaw.eu
- Illinois Governor Signs Bill Banning Intentionally Added PFAS in Certain Consumer Products and Requiring IEPA to Prepare Report on Fluoropolymers by August 1, 2027 - Bergeson & Campbell