CIRS Regulatory Newsletter | September 2026 - Newsletter

In this issue, we highlight key updates including China’s new QR code requirements for pesticide labels, upcoming EU REACH testing decisions, proposed cosmetic e-labeling in Thailand, and tighter EU contaminant limits for infant and young child foods.

We also share the latest regulatory news, upcoming deadlines, and free resources from CIRS Group to help businesses navigate changing compliance requirements around the world.

⭐Editor’s picks – key regulatory developments

China's MARA Releases the Requirements for QR Codes on Pesticide Labels

China’s Ministry of Agriculture and Rural Affairs has released detailed format and generation requirements for QR codes on pesticide labels, mandating QR Code or Data Matrix symbology, traceability URLs, and a 32‑digit unit identification code covering registration category, product registration number, manufacturing type, and specification codes. Each QR code must be unique to a single sales unit, and traceability systems must ensure accessible, accurate manufacturing and batch information. Compliance becomes mandatory on November 1, 2026.➡️Read more

10 Testing Proposals Under EU REACH Registration Set for Approval

ECHA has opened consultation on ten new REACH testing proposals involving Annex IX/X endpoints such as long‑term fish toxicity, repeated‑dose oral toxicity, developmental toxicity and in‑vivo genotoxicity. Substances include 4‑tert‑butylphenol, tetramethyl orthosilicate, several silanes and complex reaction masses. After consultation closes on October 12, ECHA will confirm testing requirements, and registrants must conduct the studies and update dossiers accordingly. Companies should review potential impacts on vertebrate testing obligations and prepare for dossier updates. ➡️Read more

Thailand Proposes Voluntary E-labeling for Cosmetics

The Thai FDA has issued a draft announcement introducing a voluntary e‑labeling system for cosmetics, enabling notifiers to present non‑essential label information electronically. Products adopting e‑labels must still display seven mandatory items on physical packaging, including product name, batch number, manufacture date, expiry date, notification number, category, and manufacturer/importer details. Small‑pack formats under 20 cm² may also use e‑labels. As the system remains voluntary, companies should monitor upcoming developments and ensure full physical‑label compliance until formal adoption. ➡️Read more

EU Tightens Maximum Levels for Three Contaminants in Infant and Young Child Foods

The European Commission has issued Regulations (EU) 2026/1825 and 2026/1890, tightening contaminant controls for 3‑MCPD, glycidyl fatty acid esters, furan and methylfurans in infant foods, edible oils and composite foods. New limits for raw oils and infant products apply from January 1, 2027, while furan and methylfuran limits take effect January 1, 2028. Composite foods with >5% fat also gain defined thresholds. Exporters should begin baseline testing, optimize oil sourcing, and adjust processing to meet the staged deadlines. ➡️Read more

Did you know we publish a slightly longer version of all our LinkedIn newsletters in the newsletter section of the CIRS Group website? You can find the previous August issue here.

🔎What’s covered in this issue – at a glance

💻Free webinars

Introduction to Hair Care Damage Models & Efficacy Evaluation

🌱Agrochemical news

China's MARA Releases the Requirements for QR Codes on Pesticide Labels

🧪Chemical news

💄Cosmetic news

🍽Food and food contact material (FCM) news

Free Webinar

Introduction on Hair Care Damage Models & Efficacy Evaluation

In the competitive global cosmetics market, substantiating your hair care product’s repair claims with robust, scientifically valid data is no longer optional—it’s a regulatory and commercial necessity. This webinar, led by Marcy Liang, delivers a deep dive into the establishment of standardized hair damage models and the cutting-edge evaluation methods used to quantify repair efficacy. ➡️Read more and register here

Agrochemical news

China's MARA Releases the Requirements for QR Codes on Pesticide Labels

Chemical news

EU Opens Public Consultation on Draft Packaging "Substances of Concern" List: Approximately 700 Chemicals Included

ECHA has published a draft list of roughly 700 “Substances of Concern” under the PPWR, covering SVHCs, chronic‑hazard substances, POPs, and chemicals that hinder recycling across plastics, paper, metals, glass, and composites. The list includes both IAS and NIAS, with common substances such as BPA, phthalates, PAHs, cadmium, lead compounds, and multiple PFAS. Stakeholders must submit use‑specific feedback by August 24. While listing does not trigger immediate bans, it will directly influence upcoming EU recyclability rules.➡️Read more

US EPA Releases Draft Risk Assessments for Dichlorobenzenes

The EPA has published draft TSCA risk assessments for o‑dichlorobenzene and p‑dichlorobenzene, finding preliminary unreasonable risks to human health from inhalation and dermal exposure across manufacturing, processing, and consumer applications. The agency is seeking detailed real‑world use information, including monitoring data, PPE practices, product composition, and model applicability. Comments must be submitted by October 9, 2026, under the relevant docket numbers. These assessments will inform future TSCA risk‑management actions.➡️Read more

Japan Amends CSCL Ordinance to Extend Name Confidentiality Period for New Chemical Substances to 10 Years

Japan’s MHLW, METI, and MOE have amended the CSCL ordinance to double the confidentiality period for new chemical substance names from five to ten years and transition public notice to online publication. Despite industry concerns raised during consultation—particularly around downstream transparency and retroactive application—the government maintained the uniform 10‑year period, citing incentives for safer chemical development. The amendment applies retroactively to all substances not yet disclosed, making timely compliance planning essential for companies handling new chemicals. ➡️Read more

China Seeks Comments on Two Mandatory GB 30000 Standards for Flammable Liquids and Oxidizing Solids

China’s MIIT has issued draft revisions to GB 30000.7 and GB 30000.15, updating flammable‑liquid and oxidizing‑solid criteria to GHS Revision 11 and converting both standards to fully mandatory requirements. Key changes include new open‑cup flash‑point rules, updated label elements, revised test methods, and added Test O.3 criteria for oxidizing solids. Once implemented—12 months after publication—companies must update GHS classifications, labels, and SDSs accordingly and use the transition period to review data and prepare for compliance.➡️Read more

US Revises HCS 2024, Extending Compliance Deadlines by Four Months

OSHA has released two correction documents to HCS 2024, addressing 44 technical and typographical errors without changing substantive obligations. Key fixes include restored reproductive‑toxicity cut‑off values and added classification content for chemicals under pressure. OSHA also extended several compliance deadlines, with substance SDS and label updates already required and mixture updates due in November 2027. Companies should continue accelerating SDS and label revisions to meet the updated timelines.➡️Read more

UK Updates GB PIC Chemicals List: Multiple POPs and Mercury-Containing Products Face Export Restrictions

The UK HSE has issued major updates to the GB PIC List, adding DecaBDE, PFOA, terbufos, carbosulfan and fenthion ULV to Part 3, expanding POP‑related export bans to substances such as PFOS, PFHxS and PCP, and prohibiting numerous mercury‑containing products under Part 5. Several entries were reclassified or deleted, and exemptions apply only in narrowly defined cases. Effective August 28, 2026, the changes significantly tighten UK export‑control requirements for chemicals and mercury‑containing goods.➡️Read more

Vietnam Seeks Comments on Draft Revisions to Three Decrees Under the New Law on Chemicals

Vietnam’s MOIT has launched public consultations on draft revisions to Decrees 24, 25 and 26, which support the new Law on Chemicals. The updates aim to streamline administrative procedures, reduce compliance burdens and address issues that emerged since the decrees took effect in January 2026. Decree 24 covers chemical lists, Decree 25 industry development and safety, and Decree 26 activity management and hazardous chemicals in products. Companies should review list impacts, monitor transitional rules and submit feedback before September 7 for Decree 24 and 25, the deadline for Decree 26 closed on August 27.➡️Read more

10 Testing Proposals Under REACH Registration Set for Approval

Japan Proposes Four New SDS Notification Items Including CAS Numbers, Comments Due September 23

Japan has opened public consultation on amendments to the Industrial Safety and Health Regulations, adding four new mandatory SDS and label notification items—including CAS numbers, respiratory protection, unsuitable glove materials, and ingredient‑level regulatory classifications. Comments close on September 23, 2026. ➡️Read more

Cosmetic news

China Existing Cosmetic Ingredient Inventory Undergoes Fifth Dynamic Adjustment, Comprehensive Review of All Five Changes Included

China’s NMPA has issued the fifth dynamic adjustment to the IECIC, moving four new cosmetic ingredients—cetyl diglyceryl tris(trimethylsiloxy)silylethyl dimethicone, nicotinamide mononucleotide, bakuchiol, and azelamidopropyl dimethyl amine—into IECIC II following completion of their 3‑year safety monitoring period. Since 2025, updates have included new ingredient inclusions, standardized INCI names, revised remarks, and expanded feedback mechanisms. With five rounds of changes now implemented, cosmetic companies should review formulations and update compliance documentation promptly. ➡️Read more

Thailand Proposes Voluntary E-labeling for Cosmetics

China NMPA Issued General Technical Requirements for Cosmetic Product Standards

China’s NMPA has released YY/T 10006‑2026, a new industry standard providing unified technical rules for drafting cosmetic product standards, effective January 1, 2027. The accompanying NIFDC Q&A emphasizes clear product‑category definitions, scientifically set technical indicators, and lifecycle‑based quality elements—including ingredient requirements, testing rules, labeling, net content, period of use, packaging, transport, and storage. Companies involved in standard formulation or revision should ensure distinct category boundaries and robust quality‑indicator design to avoid implementation confusion.➡️Read more

South Korea Passes the Cosmetic Industry Cultivation and Support Act and Amendments to the Cosmetics Act

South Korea has enacted the Cosmetic Industry Cultivation and Support Act—its first dedicated legislation for industry development—introducing five‑year national planning, an innovative‑enterprise certification system, expanded R&D and sustainability support, and comprehensive measures spanning raw materials, packaging, manufacturing, distribution, and export. Amendments to the Cosmetics Act further reinforce safety management through a new basic plan and Cosmetic Management Council. Both laws will take effect one year after promulgation, marking a significant shift in Korea’s regulatory and industrial landscape. ➡️Read more

UK SAG-CS Releases Final Safety Opinions on Seven Cosmetic Ingredients

The UK SAG‑CS has released seven safety opinions covering triclocarban, triclosan, OPP, SOPP, resorcinol, daidzein and micron‑sized particulate silver, setting updated safe‑use concentrations and identifying exclusions for oral care, sprays and child‑targeted products. The conclusions highlight regulatory divergence between the UK and EU and reinforce the need for formula checks, label‑warning reviews and monitoring of particle‑size‑specific requirements. These opinions will serve as key scientific references for upcoming UK cosmetic regulatory adjustments. ➡️Read more

China Releases the Official Guidelines on How to Write Self-Inspection Reports on Adverse Reactions to Cosmetics

China’s National Center for ADR Monitoring has released detailed guidelines on preparing cosmetic adverse‑reaction self‑inspection reports, outlining scope, general obligations, reporting timelines and required data. Serious adverse reactions must be analysed and reported within 20 days—or 10 days if socially significant—while enterprises must maintain three‑year sales and adverse‑reaction archives, conduct full‑chain cause analysis and review overseas data. The guideline’s templates support standardized reporting, and companies should establish rapid‑response mechanisms to ensure timely compliance. ➡️Read more

Indonesia Proposes Dedicated Regulation on Halal Supervisors

Indonesia has released a draft BPJPH Regulation on Halal Supervisors for WTO consultation, establishing unified qualification requirements, duties, authorities and registration procedures across food, beverage, pharmaceutical and cosmetic sectors. The draft mandates Muslim supervisors with certified halal‑law competency, defines broad supervisory powers, and introduces SIHALAL‑based registration with strict revocation rules. Existing supervisors will remain recognized but must complete compliance adjustments within two years. Comments are due by October 27, 2026.➡️Read more

Analysis Report on the Filing Status of New Cosmetic Ingredients in China – August 2026

China’s NMPA registered five new cosmetic ingredient filings in August 2026—down 64% from last year—bringing the year‑to‑date total to 139. All filings were submitted by domestic companies across four provinces, covering ingredients such as Camellia petelotii callus extract, Synotis solidaginea extract, Gymnadenia orchidis root extract, an Akkermansia fermentation lysate, and a tripeptide. Several originate from protected or medicinal plants with documented bioactive profiles. Technical requirements have not yet been disclosed.➡️Read more

Food and food contact material (FCM) news

Navigating Food and Feed Ingredients Compliance in 12 Global Markets: The White Paper Series on Novel Food & Feed Ingredients Submissions

CIRS has released a comprehensive White Paper Series addressing the regulatory challenges surrounding novel food and feed ingredients. Covering 12 major consumer and production markets, the series outlines approval pathways for novel foods, additives, feed materials, and enzymes, helping companies move beyond fragmented regulatory information. The inaugural U.S. GRAS guide offers detailed insight into FDA processes, dossier preparation, notification trends, and scrutiny of Self‑GRAS, supporting faster and more confident global market entry.➡️Read more

Available Now! White Paper Series - Guide to U.S. New Dietary Ingredient (NDI) Notifications Officially Released

CIRS has launched its Guide to U.S. New Dietary Ingredient (NDI) Notifications, completing the core regulatory roadmap for exporting new ingredients to the U.S. supplement market. With FDA rejection rates rising, the guide explains exemption criteria, dossier drafting standards, safety data requirements, submission workflows, and common pitfalls behind unsuccessful filings. Together with the U.S. GRAS guide, it provides comprehensive coverage of the two primary U.S. pathways, helping suppliers avoid compliance risks and accelerate market entry. ➡️Read more

EU Regulation 2026/196 Food Additive Rules Now Apply

Regulation (EU) 2026/196 introduces new use‑level limits and revised purity specifications for carrageenan, locust bean gum, guar gum, gum arabic, xanthan gum, pectins, and E 1450, with the strictest controls applied to infant, young‑child, and medical‑purpose foods. Several additives now have reduced or conditional authorisations, including the removal of E 412 from infant formula and time‑limited allowances for E 1450. Updated toxic‑element and microbiological criteria mean additives must meet both numerical limits and revised specifications. Transitional provisions apply to pre‑existing stocks.➡️Read more

US Market Access for Feed & Pet Food Ingredients: Compliance Q&A on the Four Major Pathways—FAP/GRAS/AFIC/SRIS

CIRS has provided a detailed overview of the four regulatory pathways for new feed ingredients in the U.S.—FAP, FDA GRAS, AFIC, and SRIS—explaining their lead authorities, recognition levels, timelines, and suitability for proprietary or commodity products. FDA GRAS remains the most balanced route, while AFIC offers confidentiality advantages and SRIS supports broad industry use. With FDA proposing to eliminate Self‑GRAS and federal recognition of post‑2024 OP additions still unclear, companies must carefully select the pathway that aligns with their data strategy and market needs. ➡️Read more

US Revises Maximum Residue Limits for Isofetamid in Certain Foods

The EPA has updated pesticide residue limits for isofetamid, increasing the MRL for shelled almonds from 0.01 mg/kg to 20 mg/kg and establishing a new 0.15 mg/kg limit for the tree‑nut crop group. Published in the Federal Register on August 4, 2026, the revisions took effect immediately and directly impact suppliers and exporters of nut‑based products. Companies shipping to the U.S. should reassess product compliance and ensure residue testing aligns with the new standards.➡️Read more

EU Tightens Maximum Levels for Three Contaminants in Infant and Young Child Foods

China Released the Implementation Q&A for China’s Administrative Measures for Food Labeling

China has released a detailed Q&A interpreting the Administrative Measures for Food Labeling, clarifying PDP identification, separate date‑marking areas, production‑date rules for multi‑layer packaging, and labeling approaches for multi‑site or group‑company manufacturing. The guidance also addresses health‑food warning‑statement formats, allergen disclosure obligations, and trademark‑area restrictions for imported products. These clarifications provide operational direction for food manufacturers and importers seeking to standardize labeling practices and ensure full regulatory compliance.➡️Read more

South Korea's MFDS Revises the Enforcement Rules of the Food Sanitation Act, Significantly Increasing Official Fees for Temporary Recognition of Food Ingredients

South Korea’s MFDS has revised the Enforcement Rules of the Food Sanitation Act, significantly increasing fees for temporary recognition of food ingredients (KRW 100,000 → 3 million) and GM food safety reviews (KRW 5 million → 8.5 million). MFDS states the higher fees will fund expanded review personnel and expert consultations to improve efficiency and shorten timelines. While submission costs rise, enhanced review capacity may accelerate market entry for novel and genetically modified ingredients. CIRS Korea can assess applicable fee categories.➡️Read more

China's CFSA Collects Public Opinions for 3 New Food Ingredients

China’s CFSA has issued three new food materials for consultation: Sanghuangporus mycelium (≤5 g/day, with proportional adjustment based on polysaccharide content), Aloe vera gel (anthraquinone‑removed, with updated safety notes), and Rhodotorula toruloides oil (≤2.5 g/day, with defined fatty‑acid and contaminant limits). All three exclude infants, young children, pregnant and breastfeeding women, and require clear labeling of unsuitable populations. Stakeholders may submit comments before September 30, 2026. ➡️Read more

Why Choose CIRS for Novel Food and Feed Ingredients Registration?

As regulatory requirements for novel food and feed ingredients grow more complex across China, the U.S., the EU, and Asia‑Pacific, CIRS provides globally integrated compliance support backed by 450+ staff, advanced toxicology capabilities, and extensive successful cases. With expertise spanning synthetic biology, multi‑market submissions, GRAS, EU Novel Food, China’s Three New Foods, and global feed pathways, CIRS delivers unified strategies, scientific dossier development, and one‑stop regulatory, testing, and data services to accelerate international market entry. ➡️Read more

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