On July 10, 2026, the Governor of Illinois signed the Chemicals in Cosmetic Products Act (HB 3409) into law, prohibiting the manufacture, sale, delivery, holding, or offering for sale of cosmetic products containing 24 specific “intentionally added” ingredients, effective July 1, 2028.

Background

In recent years, in addition to the federal Modernization of Cosmetics Regulation Act (MoCRA, 2022), various US states have successively enacted cosmetic ingredient bans and restrictions. Illinois' Chemicals in Cosmetic Products Act was passed by the 104th General Assembly (HB 3409) and is intended to reduce hazardous chemicals in cosmetics associated with cancer, reproductive harm, and other health risks.

Key Contents

1. Prohibition of 24 “Intentionally Added” Ingredients (Section 15(a))

The following 24 substances (11 named chemicals + 13 PFAS and their salts), when used as “intentionally added” ingredients in cosmetics, are prohibited. The complete list and CAS numbers are as follows:

2. Scope and Trace Quantity Exemption (Sections 10, 15(b))

“Cosmetic product” covers makeup, hair products, nail products, soaps and lotions, tanning products, and perfumes and eau de cologne, and incorporates the definition of “cosmetic” under the US Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321). Additionally, where a product is manufactured through a process intended to comply with this Act and contains a “technically unavoidable trace quantity” of a listed ingredient solely due to impurities of raw materials, the manufacturing process, storage, or packaging, it is not deemed a violation.

3. Effective Date (Section 99)

This Act takes effect on July 1, 2028, providing the industry with approximately a two-year transition period for formulation adjustment and compliance.

About CIRS

Established in 2007, the CIRS Group is a leading product safety and regulatory consulting firm. CIRS has branch offices in the Republic of Ireland, South Korea, the United States, the United Kingdom, Japan and China. CIRS Group utilizes its technical expertise, various resources, and international network to provide one-stop compliance services from regulatory compliance, laboratory testing, R&D to data services across multiple industries. This includes chemicals, cosmetics, food and food beverages, medical devices, agrochemical products, disinfectants, and consumer goods. It helps clients gain a competitive advantage by reducing business risks associated with regulatory affairs.

The CIRS cosmetic team provides expert support to ensure that cosmetic products meet stringent global cosmetic regulations and safety standards. 

We offer comprehensive, lifecycle-based solutions for personal care products, from early-stage cosmetic ingredient development through to final product registration. Our services include:

• Cosmetic ingredient development and regulatory strategy,
• Physical/chemical and analytical tests, 
• Toxicological tests (in vivo & in vitro),
• Efficacy and claim substantiation studies (in vivo & in vitro), and
• Ingredient and product registration across global markets.

With deep expertise in cosmetic regulatory compliance and safety evaluations, our team enables brands to bring products to market efficiently and with confidence.

Our Services

• The United States Agent
• The United States FDA Cosmetic Facility Registration
• The United States FDA Cosmetic Product Listing
• The United States FDA OTC Drug Registration
• The United States Color Additive Batch Certification
• The United States Cosmetic/OTC Drug Labeling Review
• International Cosmetic Ingredient Name (INCI) Application

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further  information

Illinois Government