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The Ministry of Agriculture and Forestry of Turkey, through the General Directorate of Food and Control (Gıda ve Kontrol Genel Müdürlüğü), has published the draft regulation titled “Türk Gıda Kodeksi Gıda ile Temas Eden Madde ve Malzemelere Dair Yönetmelikte Değişiklik Yapılmasına Dair Yönetmelik” which proposes amendments to the existing regulation on materials and articles in contact with food. Table of contents Main points of the draft Implications Türkiye: Official changes to allow recycled plastics in contact with food Main points of the draft These are the changes the draft proposes, according to the official text: Elimination of the ban on the use of recycled plastics. The current regulation prohibits the use of recycled plastics in materials and articles that come into contact with food. The draft proposes eliminating this ban. New rules for production scraps and surpluses ("çapak ve kenar fireleri"). Additional rules will be introduced for the reprocessing of chips, trimmings, or surpluses that arise during the plastic manufacturing process. This is intended to control internally generated waste before it is converted into food-safe recycled material. Updating legislative references The draft also contemplates updating the references to current legislation, that is, the articles, rules, or decrees cited in the regulation, to align them with more recent standards or applicable international regulations. Public Comment Deadline The draft invites public comments. The deadline for submitting these comments is September 30, 2025 . Implications With the data from the draft, some important implications can be foreseen , although this will depend on the final wording approved by the government: Sustainability improvements : If approved, this measure would promote wider use of recycled plastic, potentially reducing plastic waste and increasing reuse, provided safety controls are in place. Stricter technical requirements : To avoid risks, the new rules for production waste will involve stricter requirements regarding traceability, cleaning, chemical testing, substance migration control, etc. Industry Adaptation : Companies that could benefit or be affected will need to adapt their processes if they want their recycled materials to be suitable for food contact under the new standards. Consumer Protection : The change aims to maintain food safety, but effective regulatory controls will be crucial to ensure that recycled products actually meet the necessary criteria. Get in touch with a cosmetic regulation expert today

On 1 September 2025, Regulation (EU) 2024/1976, known as Omnibus VII, which amends the annexes to Regulation (EC) No 1223/2009 on cosmetic products, came into force. This update incorporates new restrictions arising from the classification of substances as carcinogenic, mutagenic or toxic for reproduction (CMR), in line with the CLP Regulation (Regulation (EC) No 1272/2008). Table of contents Affected substances Regulatory implications Regulatory context Conclusion Omnibus VII: Prohibition of TPO and DIMETHYLTOLYLAMINE in the European Union Affected substances From this date, cosmetic products containing the following substances may not be placed on the EU market: Trimethylbenzoyl Diphenylphosphine Oxide (TPO) N,N-Dimethyl-p-toluidine (DIMETHYLTOLYLAMINE) Both compounds have been classified as CMRs and, therefore, their use in cosmetics is prohibited unless they have been specifically evaluated and authorized under very specific conditions, which has not occurred. Regulatory implications The entry into force of Omnibus VII implies: Immediate withdrawal from the market of any cosmetic product containing these substances. Direct responsibility of companies (manufacturers, importers, distributors) to verify formulas, update the Product Information File (PIF) and ensure that non-compliant products are not marketed. Administrative sanctions and risks of product recall in the event of non-compliance by the competent authorities of each Member State. Regulatory context The Omnibus Regulations are published periodically to automatically integrate substances classified as CMRs under the CLP Regulation into European cosmetics regulations. This mechanism ensures that the list of prohibited ingredients remains up-to-date based on scientific and regulatory developments. Conclusion Omnibus VII strengthens consumer health protection by removing substances with an unacceptable toxicological profile from the market in cosmetics. For the sector, this measure requires constant monitoring of regulatory updates and the obligation to proactively review formulations. Compliance with these provisions not only avoids sanctions but also strengthens confidence in the safety of products offered in the European Union.

On June 20, 2025, the Spanish Government notified the EU Technical Regulations Information System (TRIS) of a draft Royal Decree seeking to regulate accessible labeling for consumer products, including cosmetics, with the aim of improving the safety, integrity, and quality of life of people with visual impairments. Table of contents Content and scope of the preliminary draft Deadline for public participation Implications for the cosmetics sector Conclusion Accessible Labeling Requirements for Cosmetics in Spain Content and scope of the preliminary draft This draft establishes that products must incorporate: Accessible labeling in the form of Braille, QR code, or other similar system. A tactile mark on the packaging to easily locate the QR code. That the information must be available, at least, in Spanish. Deadline for public participation The procedure is currently under public comment; interested parties can submit comments until September 23, 2025. Implications for the Cosmetics Sector Design and innovation The incorporation of accessible technologies such as Braille or QR codes requires a serious review of packaging design. Companies must ensure that labeling is functional for all consumers, including those with visual impairments. Inclusive dimension This regulatory measure responds to a growing regulatory awareness of the need for more inclusive products, ensuring that information on safety, use, and composition is accessible to all. Opportunity to participate The consultation phase, open until September 2025, is a valuable opportunity for the sector to provide technical and operational feedback and actively contribute to the final formulation of the regulation. Conclusion The draft Royal Decree on accessible labeling in cosmetics represents a significant step forward in terms of inclusion and accessibility in Spain. The requirements to implement Braille, QR codes, and tactile markings, along with the obligation to present information in Spanish, demonstrate the commitment to protecting consumers with visual impairments. The public consultation period, until September 23, 2025, marks a key point for the industry to engage in a constructive and transparent dialogue.

On July 10, 2025, the European Commission adopted Implementing Decision (EU) 2025/1175, updating the Glossary of Common Names of Ingredients used in cosmetic products. This glossary is a fundamental reference tool for ensuring labeling harmonization in the European market and is included in the framework of Regulation (EC) No. 1223/2009 on cosmetic products. Table of contents Table of contents Contents of the update Entry into force and application Implications for the cosmetics sector Conclusion Updated: Eropean Union Glossary of Ingredients Common Names Contents of the update The new version of the glossary includes: Increase in the number of entries: from 30,070 to 30,419 terms. Incorporation of new INCI names, in line with updates from the Personal Care Products Council . Linguistic corrections and normalization of previously erroneous or incomplete terms. Elimination of obsolete terms, replaced by more recent and standardized names. These amendments aim to strengthen consistency and precision in the naming of ingredients, reducing potential ambiguities for economic operators, competent authorities, and consumers. Entry into force and application The decision took effect on July 30, 2025. It will be mandatory from July 30, 2026, after the twelve-month transition period provided by the Commission. During this period, companies will be able to voluntarily adopt the new nomenclature on their labels, facilitating a gradual transition to the new regulatory framework. Implications for the cosmetics sector The use of standardized common names has several regulatory and practical consequences: Legal certainty: By using harmonized terminology, companies reduce the risk of regulatory non-compliance in labeling. Transparency for the consumer: Uniformity of terms makes it easier to identify ingredients, especially in a context of growing interest in the composition of cosmetics. International consistency: The update maintains alignment with globally recognized nomenclatures (INCI), which favors the competitiveness of European companies in foreign markets. Conclusion The publication of Implementing Decision (EU) 2025/1175 and the subsequent update of the Glossary of Common Names of Ingredients represent a significant step in improving the European cosmetics regulatory framework. This measure strengthens transparency, legal certainty, and consumer protection, while offering the industry a reasonable adaptation period to comply with the new requirements. With its mandatory entry into force in July 2026, the European cosmetics industry will have to ensure that all labels comply with the new designations, thus consolidating a clearer, more coherent, and more accessible market for all stakeholders.

On August 20, 2025, the European Commission published version 5.5 of the EU Border Products Manual, now available for download. Table of contents What's new in this update? Why is this manual important? EU: Version 5.5 of the Borderline Manual What's new in this update? High expectations for clarity: The EU Cosmetics Working Group's Subgroup on Border Products added two key new entries to the manual: “Self-tanning concentrates” now included in section 1.10 “Oral drops, sprays or gels” added as section 2.4 CTPA Precise retitling and replacement: The former section 2.4 “Nasal sprays” has been renumbered as 2.5. Section 3.3.22 has been replaced with a new entry dedicated to tattoo removal or fading products. Why is this manual important? The Frontier Products Manual helps clearly delineate when an item is classified as a cosmetic —and therefore regulated under Regulation (EC) No 1223/2009—or whether it should be governed by rules from another sector single-market-economy.ec.europa.eu . This avoids legal and commercial confusion among companies, regulatory authorities, and consumers.

On August 1, 2025, the Court of Justice of the European Union (CJEU) upheld the annulment of the classification of titanium dioxide (TiO₂) as a possible inhalation carcinogen, a decision that marks a significant shift in the regulation of this ingredient used in various industrial, cosmetic, and food products. Table of contents Case Context Regulatory Implications What does this ruling mean for the industry? Final Reflection What do you think about this decision? Declassification of Titanium Dioxide in the European Union Case Context Titanium dioxide powder (particle size ≤10 μm and concentration above 1%) was classified in 2019 as a suspected inhalation carcinogen under CMR (Carcinogen, Mutagen, Reprotoxic) Category 2. This classification was adopted by the European Chemicals Agency (ECHA) based on the opinion of the ECHA Committee for Risk Assessment (RAC) issued in 2017. However, this classification was subsequently annulled by the General Court of the EU in 2022 due to a lack of sufficient scientific evidence to justify this status. Faced with this annulment, both the European Commission and France appealed to the CJEU, which ultimately upheld the decision, stressing that there was no conclusive scientific evidence to support the classification of TiO₂ as an inhalation carcinogen. Regulatory Implications This ruling has a significant impact on several key regulations, particularly in the area of REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation) and the classification procedures under the Globally Harmonized System (GHS) and CLP (Classification, Labelling and Packaging of Substances and Mixtures Regulation). For the cosmetics industry and other sectors that use titanium dioxide in their products, the repeal of this classification could simplify regulatory processes, as it eliminates the need to comply with additional restrictions that would otherwise have limited the use of TiO₂ in certain formulations. Furthermore, the decision could facilitate the safety management of TiO₂, particularly in cosmetics and food products, by reducing requirements for risk management and the implementation of protective measures in the workplace. What does this ruling mean for the industry? For the industry, this ruling could be considered a victory, as it removes one of the regulatory barriers to the use of TiO₂ in cosmetics and other consumer goods. While companies will still need to ensure the safety of their products, the decision could offer greater clarity and flexibility in the management of substances like TiO₂. However, it is also important to emphasize that, although TiO₂ has been declassified as a carcinogen, the court emphasized that this does not mean that titanium dioxide is completely safe. Authorities will continue to monitor the use of this substance, and further scientific safety assessments are expected. Final Reflection This change in the classification of titanium dioxide highlights the importance of basing regulatory decisions on sound and up-to-date scientific data. The ruling also underscores the dynamics between science, politics, and regulation, and how these interactions can have a direct impact on businesses and consumers. At Belab Services, we closely monitor these regulatory developments to ensure our clients are always up to date with the latest regulatory changes and can efficiently adapt to an ever-evolving regulatory environment. What do you think about this decision? Do you think this is a victory for science or industry, or a balance of both? We invite you to share your thoughts with us in the comments. Contact a cosmetic regulatory expert

Marketing cosmetic products in international markets requires compliance with distinct and sometimes divergent regulatory frameworks. While the European Union is governed by a harmonized EU regulation (Regulation (EC) No. 1223/2009), the United States recently reformed its legislation with the passage of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), which amends the Federal Food, Drug, and Cosmetic Act (FD&C Act). This article provides a structured comparison of the main requirements in both countries. Table of contents General regulatory framework Market access Safety and GMP evaluation Control of ingredients Labeled Nanomaterials Market surveillance and adverse effects Animal testing Claims Diferencias entre la normativa cosmética de Estados Unidos y la Unión Europea 1. General regulatory framework European Union The applicable legislation is Regulation (EC) No. 1223/2009, which is directly applicable in all Member States. It lays down detailed rules on safety, technical documentation, pre-market notification, labeling, permitted/restricted ingredients, market surveillance, and legal liability. United States The primary legal framework is the FD&C Act, updated through MoCRA. For the first time, it introduces a more robust structure for cosmetics, including establishment registration requirements, product listing, safety documentation, adverse event management, and mandatory recall authority from the FDA. 2. Market access Requirement European Union USA Legal designation Responsible Person (RP) in the EU mandatory Responsible Person (who appears on the label) Obligation of domicile PR must be established in the EU May be outside the US if it meets label requirements Pre-marketing Mandatory CPNP notification Product listing in FDA (MoCRA) Technical documentation PIF with mandatory CPSR Safety substantiation documented, not fixed format Foreign manufacturing No additional intermediary required Requires US Agent for foreign installation Note: Responsible Person (EU) and Responsible Person (US) are not equivalent or interchangeable. Furthermore, the US Agent is a requirement solely related to the registration of foreign facilities with the FDA, not to product liability. 3. Safety and GMP evaluation EU: The PR must ensure the product safety assessment and prepare a Cosmetic Product Safety Report (CPSR) in accordance with Annex I of the Regulation. The product must be manufactured according to Good Manufacturing Practices (GMP), preferably in accordance with the harmonized standard ISO 22716. U.S.: MoCRA requires adequate documentation supporting product safety, which must be maintained and available for inspection by the FDA. Specific federal GMP regulations for cosmetics are currently under development. 4. Control of ingredients EU: The regulation includes five binding annexes: Annex II : prohibited substances Annex III : Restricted Substances Annex IV, V and VI : positive lists of permitted colorants, preservatives and UV filters The Commission periodically updates these annexes based on opinions from the SCCS (Scientific Committee on Consumer Safety). USA : There is no general negative or positive list for cosmetics, except for colorants , which do require prior FDA approval . Many require batch certification before use. 5. Labeling Mandatory in the EU (Article 19 of Regulation 1223/2009): Name and address of the Responsible Person Nominal content Minimum Duration Date or PAO Batch number List of ingredients (INCI) Product function (if not obvious) Indication of nanomaterials with “[nano]” Individual declaration of fragrance allergens above thresholds (updated in 2023 by Regulation (EU) 2023/1545) Mandatory in the USA (MoCRA and 21 CFR 701): Product identity Net content List of ingredients Name and address of the Responsible Person Contact information for reporting adverse events: physical or electronic address pursuant to § 609(a) (Coming soon) : Future regulation on fragrance allergens in development 6. Nanomaterials EU : They require specific prior notification (Article 16) and must be labeled as “[nano].” Only nanomaterials assessed by the SCCS and authorized by the Commission are permitted. USA : There are no specific regulations for labeling nanomaterials, although the FDA monitors their use in cosmetics through best practice guidelines. 7. Market surveillance and adverse effects EU : The PR is required to report Serious Undesirable Effects (SUE) to the competent authority of the Member State. Authorities may order the withdrawal or suspension of non-compliant products. U.S.: The Responsible Person must report serious adverse events to the FDA within 15 business days and retain records for at least six years. MoCRA grants the FDA the authority to order mandatory recalls of products that pose serious risks. 8. Animal testing EU : There is a total ban on animal testing for finished cosmetics and ingredients for exclusively cosmetic purposes (Article 18). USA : Although the use of animals is not required to demonstrate the safety of a cosmetic, there is no blanket federal ban. Some states (such as California) have adopted stricter restrictions. 9. Claims A key difference between cosmetic regulations in the European Union (EU) and the United States (US) lies in how claims used in product marketing are controlled and permitted. European Union In the EU, cosmetic claims are very precisely regulated under Regulation (EU) No. 655/2013, which establishes common criteria for justifying claims on cosmetic products. Claims must comply with six fundamental principles: Legal compliance Truthfulness Evidence Sincerity Fairness Informed decision-making In addition, all claims must be justified by adequate and verifiable evidence. It is not permitted to attribute properties to the product that it cannot fulfill, nor to confuse the consumer with exaggerated or unsupported claims. The use of “free from” claims (e.g., paraben free) is also regulated. However, Europe generally allows a wider range of claims and assertions of effects in cosmetics than the US. United States In the US, the FDA only allows cosmetic claims restricted to cleansing, moisturizing, and improving the overall appearance of the skin, prohibiting any type of claim that affects the functioning or structure of the skin or, of course, medical claims. Furthermore, the line between a cosmetic and an over-the-counter drug in the US is very fine, and using terms common in Europe such as “anti-acne,” “anti-aging,” or with structural or functional properties can automatically place the product under the regulation of Drugs or OTCs. Conclusion: two regulatory frameworks with different approaches EU regulations are more prescriptive, with well-defined pre-marketing requirements and legally responsible figures. The US system, now modernized with MoCRA, is moving toward stricter documentation requirements, although it remains more flexible in certain areas. For companies operating in both markets, it is essential: Align technical documentation (PIF vs. safety substantiation) Create labeling tailored to each jurisdiction Check ingredients and colorings according to the specific lists Have a US Agent and a qualified PR if manufactured outside the respective territories Official sources Regulation (EC) No 1223/2009 – Official Journal of the EU Regulation (EU) 2023/1545 – New fragrance allergens FDA – Modernization of Cosmetics Regulation Act (MoCRA) FDA – Product Facility Registration and Listing Guidance FDA – Cosmetic Labeling Guide (21 CFR 701) FDA – Guidance on Nanotechnology in Cosmetics European Commission – CosIng, SCCS, ISO 22716

Brussels, July 2025 – Following several years of scientific evaluation and accumulation of toxicological evidence, the European Union's Scientific Committee on Consumer Safety (SCCS) has issued a conclusive opinion on the use of prostaglandin analogues in cosmetic products intended to stimulate the growth of eyelashes or eyebrows. According to the final opinion published in 2025, the following substances cannot be considered safe for cosmetic use: Ethyl Tafluprostamide Methylamido-Dihydro-Noralfaprostal (MDN) Isopropyl Cloprostenate (IPCP) Table of contents Background: A growing concern since 2018 Reasons for the decision: reproductive and pharmacodynamic risks Next regulatory steps SCCS: Declares Several Prostaglandin Analogues Unsafe Background: A growing concern since 2018 The initial alert was issued in 2018 by the German Federal Institute for Risk Assessment (BfR), which warned the European Commission about the increasing and unregulated use of these compounds in cosmetic products for eyelash growth. These ingredients, derived from prostaglandins, exhibit potent pharmacological activity, which puts them far from the expected safety profile in everyday cosmetic products. At the time, none of these compounds were regulated under Regulation (EC) No 1223/2009 on cosmetic products. Following the concerns raised, the SCCS initiated a systematic evaluation of their toxicological profile. Reasons for the decision: reproductive and pharmacodynamic risks The SCCS concluded that even at low concentrations, these prostaglandin analogues can induce significant biological effects, posing a risk to consumer health. Furthermore, a lack of reliable data was identified that would rule out adverse effects on reproduction and embryonic or fetal development. Therefore, in line with the precautionary principle and the requirements of the Cosmetics Regulation, the Committee ruled that these substances should not be used in cosmetic products, especially those intended for sensitive areas such as the eyes. Next regulatory steps Following this opinion from the SCCS, the European Commission is expected to update the Annexes to Regulation 1223/2009, including these substances in Annex II (list of prohibited ingredients) or introducing clear restrictions in Annex III. This case reinforces the importance of scientific evaluation prior to the use of ingredients with pharmacological potential in cosmetic products , and sets a precedent for future regulation of "borderline" active ingredients — that is, ingredients that lie at the boundary between cosmetics and medicine.

Brussels, July 11, 2025 – The European Commission this week presented a legislative proposal to reform Regulation (EC) No. 1223/2009 on cosmetic products. This initiative, part of a broader regulatory simplification package for chemical products, responds to growing concerns in the cosmetics sector regarding the interpretive rigidity of the current legal framework and the obstacles it poses to innovation. Table of contents Context: accumulated demands of the sector Main proposed amendments Additional simplification and regulatory coherence Next steps The European Commission proposes a reform of the Cosmetics Regulation Context: accumulated demands of the sector Since its entry into force in 2013, the Cosmetics Regulation has been the subject of criticism from stakeholders, who have warned of an increasing administrative burden and a lack of flexibility in the application of certain provisions. Among the main areas of concern is the classification of ingredients of natural origin—such as tea tree oil or spearmint oil—as CMR substances (carcinogenic, mutagenic, or toxic to reproduction), which has significantly impacted product formulations, especially those based on fragrances derived from essential oils. Other pain points identified by the industry include the lack of consideration of exposure type in toxicological assessments, delays in reporting nanomaterials, and the infrequent updating of the glossary of authorized ingredients. Main proposed amendments Among the most significant changes proposed by the Commission is the introduction of a new Article 14a, which will establish a clear procedure for applying for the inclusion of substances such as colorants, preservatives, or UV filters in the regulation's annexes. This amendment aims to provide greater transparency and legal certainty for companies wishing to introduce new substances to the market. Regarding the controversial Article 15, relating to CMR substances, the proposal clarifies that the prohibition on use will only apply when the hazard is based on dermal exposure. Thus, if a substance presents risks only through ingestion or inhalation, it would not be automatically excluded from cosmetic products. Likewise, the aim is to streamline the exemption process for substances classified as CMR 1A or 1B, without abandoning the precautionary principle that governs the use of these compounds in cosmetics. Another important development is the elimination of the prior notification requirement for nanomaterials, as set out in Article 16. From now on, information regarding these components must be included directly in the product safety report, under the responsibility of the Responsible Person. Additional simplification and regulatory coherence The Commission has also proposed the deletion of Article 33, thereby eliminating the glossary of common names for ingredients. From now on, the INCI nomenclature, which has already been standardized internationally, will be widely adopted. For its part, Article 22 will no longer require Member States to provide periodic reports on market surveillance, considering that the ICSMS system already covers this function effectively and in real time. Finally, Annex I of the Regulation will be updated to more precisely specify the information that must be included on nanomaterials in the safety report, such as chemical name (IUPAC), particle size, and physical and chemical properties. Next steps The proposal will now be assessed by the European Parliament and the Council of the European Union within the ordinary legislative process. The Commission hopes that these reforms will contribute to a more balanced regulatory environment that protects consumer health without hindering the competitiveness and innovation of the European cosmetics industry.

Brussels, July 17, 2025 – The European Commission has decided to refer France to the Court of Justice of the European Union (CJEU) over its national waste separation labeling regulations, specifically the requirement to include the Triman logo and the "infotri" supplementary information on products subject to extended producer responsibility (EPR). According to the European Commission, this regulation imposed by France violates Articles 34 to 36 of the Treaty on the Functioning of the European Union (TFEU), as it constitutes a barrier to the free movement of goods within the internal market. The Commission argues that, in the absence of harmonized rules on waste separation labeling at the European level, the imposition of a national system like the French one forces manufacturers in other Member States to modify their packaging exclusively for the French market, which represents an unjustified obstacle to intra-European trade. Table of contents Disproportionate obligations and lack of notification A long process with a history The end of Triman as we know it? Triman Logo: Brussels takes France to the CJEU over its waste labeling regulations Disproportionate obligations and lack of notification Beyond the incompatibility with the single market, the Commission considers that France has failed to comply with the prior notification obligation established by Directive (EU) 2015/1535 on transparency in the internal market by failing to provide information on the content of this measure before its adoption. In its analysis, the European Executive also points out that there are less restrictive alternatives for informing consumers about how to classify waste, without the need to impose exclusive labels for a single country. This issue will be subject to future harmonization within the framework of the new Regulation on Packaging and Packaging Waste, which provides for specific implementing acts on this matter. A long process with a history The infringement came as no surprise: the Commission had already sent a letter of formal notice to France in February 2023, followed by a reasoned opinion in November 2024. Since no corrective measures were adopted, the Court of Justice of the European Union (CJEU) was ultimately consulted. The measure is part of the Commission's strategy to ensure the effective functioning of the single market , as highlighted in the recent Communication COM(2025)500, which focuses on removing barriers affecting the competitiveness of European businesses and consumer rights. The end of Triman as we know it? The Triman logo, mandatory in France since 2022 to indicate the recyclability of products, has been a source of controversy in sectors such as cosmetics, food, and packaging. Its possible invalidation at the European level would mark a turning point in environmental labeling policy and highlights the need for unified standards for all Member States. For now, the future of Triman will depend on the Court's ruling, but the message is clear: the Commission will not tolerate national regulations that hinder intra-European trade without a proportional and harmonized basis.

In a recent move, the state of Minnesota has decided to extend the reporting deadline for per- and polyfluoroalkyl substances (PFAS) in products. Originally set for January 2026, the new deadline will be July 1, 2026. This measure, announced by the Minnesota Pollution Control Agency (MPCA), seeks to give manufacturers more time to adapt to new regulatory requirements on PFAS, which are part of a broader effort to reduce PFAS pollution in the state. Table of contents What Are PFAS and Why Are They Important? Amara's Law and Its Impact on Manufacturers What This Means for Manufacturers Key Dates for Manufacturers Considerations for Businesses In summary Minnesota Extiende la Fecha Límite para la Presentación de Informes sobre PFAS en Productos What Are PFAS and Why Are They Important? PFAS are a group of synthetic chemical compounds used in a variety of products due to their water-, oil-, and heat-resistant properties. They are commonly found in items such as carpets, cleaning products, cosmetics, kitchen utensils, and personal hygiene products. However, their accumulation in the environment and in humans has raised concerns about potential health and environmental risks, leading to the imposition of new regulations. Amara's Law and Its Impact on Manufacturers The extension of the filing deadline falls under the Amara Act, enacted in May 2023, which prohibits the sale and distribution of products containing intentionally added PFAS in several categories, including: Carpets and rugs Cleaning products Cosmetics Dental floss Menstruation products Upholstered furniture Additionally, the law requires manufacturers to report to the MPCA products containing PFAS, detailing concentrations and other specific characteristics. Starting January 1, 2025, the first bans on PFAS in products will take effect. This legislation seeks a gradual transition toward a complete ban on intentionally added PFAS by January 1, 2032, unless deemed unavoidable for the safety or functionality of certain products. What This Means for Manufacturers Manufacturers will be required to comply with new PFAS reporting requirements through the Minnesota PFAS Information and Reporting System (PRISM), which is expected to be available for testing in fall 2025. The six-month extension to the reporting deadline will allow companies to establish agreements with their suppliers to report products on their behalf and give them additional time to familiarize themselves with the new platform. Key Dates for Manufacturers Compliance with the new regulations requires manufacturers to be aware of the following deadlines: January 1, 2025 : PFAS bans begin in certain products. Fall 2025 : Testing of the new reporting platform (PRISM). July 1, 2026 : Deadline for submission of initial PFAS reports. February 1, 2027 : First annual updates or recertifications. January 1, 2032 : Complete ban on intentionally added PFAS in all products sold in Minnesota, with some exceptions. Considerations for Businesses With the new extension, companies have additional time to comply with the requirements and adapt to the new regulations. It is essential that manufacturers begin collecting data on their products as soon as possible to ensure compliance with the 2026 deadline. Furthermore, they must be prepared to make annual updates to the information provided, including recertification of products containing PFAS. In summary Minnesota's decision to extend the PFAS reporting deadline reflects an effort to ease the transition to stricter regulations aimed at reducing exposure to these potentially harmful chemicals. Manufacturers must stay informed and meet established deadlines to avoid penalties and ensure their products comply with state law. The PRISM platform will be a key tool in this process, and its implementation in 2025 will be critical to facilitating compliance with the new rules. As the July 1, 2026, deadline approaches, businesses must ensure they are prepared for data collection and reporting in accordance with the new regulations to avoid any setbacks. Contacta con un experto en regulación cosmética

On 20 June 2025, the Official Journal of the European Union published Delegated Regulation (EU) 2025/1222, which constitutes the 23rd Adaptation to Technical Progress (ATP) of Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP). The regulation adds 22 substances to Table 3 of Annex VI and replaces 10 existing entries, incorporating the most recent opinions from ECHA's Risk Assessment Committee (RAC). The regulation will enter into force on July 10, 2025, and will be mandatory from February 1, 2027, although providers may adopt it voluntarily from the date of entry into force. Table of contents Regulatory overview Main technical innovations Regulatory implications for businesses Strategic recommendations from BELAB Services 23.ª ATP al Reglamento CLP: UE introduce 22 nuevas entradas y revisa 10 clasificaciones armonizadas 1. Regulatory overview Objective : To align the harmonized classification with current toxicological evidence, strengthening the protection of human health and the environment. Legal basis : Articles 37(5) and 53 of the CLP Regulation. Transition period : 19 months to consume stocks and adapt labels, SDS and UFI/PCN notifications. 2. Main technical innovations Group of substances (examples) Essential change in danger Affected sectors Oxidants and industrial gases O₃ (ozone), N₂O (nitrous oxide) New entries with multiple classes: Ox. Gas 1 , Acute Tox 1 , STOT RE 1 , Carc. 2 , Ozone 1 Water treatment, semiconductors, hospitals Organic intermediates 1,1-dichloroethylene (vinylidene chloride) Reclassification to Carc. 2 and STOT SE 3 Barrier plastics, adhesives Agrochemicals / biocides Captan, Folpet, Dinotefuran, Pethoxamid Inclusion or hardening of Carc. , Repr. or Aquatic Chronic 1 classes Phytosanitary products, pest control Pigments and dyes Pigment Red 53:1 Classification Carc. 1B (change from “suspected” to “alleged”) Inks, artistic and signage paints Botanical extracts Chrysanthemum cinerariaefolium (pyrethrin) New STOT SE 1 classification and specific limits (ATE, M-factors) Natural cosmetics, gardening products 3. Regulatory implications for companies Classification and Labeling : Manufacturers and importers must relabel containers and update GHS pictograms by February 1, 2027. Safety Data Sheets (SDS) : Revise sections 2, 9 and 11 to reflect new classes, specific limits and M-factors. PCN/UFI Notifications : Any affected mixture requires new or amended submission to the national Poison Control Centres. Supply chain transparency : communicating hazard changes to upstream and downstream customers, especially when formulations are linked. Substitution : Initiate analysis of alternatives for substances classified as Carc. 1B / Repr. 1B to avoid future restriction or authorization scenarios. 4. Strategic recommendations from BELAB Services Priority action Aim Suggested deadline Inventory audit Detect impacted substances and mixtures in all centers and subsidiaries Q3 2025 Contract management Incorporate liability clauses and provide updated CLP data Q4 2025 Internal training Train R&D, regulatory affairs, and marketing on labeling changes Continuous External communication Proactively inform customers about the transition and benefits of early adoption From July 2025 Our multidisciplinary team can assist you with: Multilingual relabeling in compliance with CLP/GHS. Comprehensive review of SDS and adaptation to IUCLID 6. Replacement strategies and risk-benefit profile. PCN communication and support in market inspections. Request more information at consut@belabservices.com .