Navigating a Shifting U.S. Regulatory Landscape

Over the past year, U.S. ingredient suppliers and brand owners have faced a regulatory environment that is evolving in two directions: federal modernization and state-level fragmentation. This dynamic impacts operations, costs, transparency demands, compliance, and supply chains throughout the cosmetics and personal care products industry.

While implementation of the Modernization of Cosmetics Regulation Act (MoCRA) continues, state-level proposals targeting ingredients and packaging keep emerging, creating a patchwork of rules that reshape day-to-day realities for suppliers, formulators, and compliance leaders.

Supply chains must deliver rigorous safety and transparency while adapting to divergent requirements, often under compressed timelines.

One Market, 50 Playbooks

The patchwork of state policies can impose costly and confusing compliance standards.

A single raw material may be permissible in one state but restricted in another. Packaging claims and recycling calculations vary by statute, and monograph-adjacent products (such as certain sunscreens or anti-acne topicals) face inconsistent labeling requirements.

To manage this complexity, companies now rely on multi-layered protocols for supplier qualification, document collection (safety dossiers, impurity profiles, allergen content, residual levels), and change control, while meeting MoCRA’s national requirements. Teams across R&D, regulatory, quality, legal, and procurement must ensure audit-ready evidence and state-specific compliance gates before commercialization.

In 2025 alone, PCPC monitored more than 200 bills in over 30 states, each with language that could impact the industry. Even when outcomes are favorable, companies track these developments closely. For suppliers, this means tighter forecasting, dualsourcing strategies, and earlier technical engagement with brand owners to validate alternatives that meet the strictest applicable standards.

Rising Expectations for Transparency

Regulators, retailers, and consumers are demanding unprecedented levels of transparency. Suppliers are now asked to provide detailed information on manufacturing processes, impurity profiles, residual solvent limits, and allergen content. Brands are translating this technical data into clear, consumer-friendly language to build trust. But when states redefine product categories or claims, companies must pivot quickly to maintain compliance and clarity.

Certification and Standards

Market access increasingly depends on certifications and retailer-driven requirements. Suppliers often maintain detailed restriction matrices that track ingredient status, certification constraints, and retailer lists by jurisdiction. Close collaboration with formulators is essential.

This shift is permanent. Companies are expanding teams of regulatory scientists, toxicologists, and quality specialists to keep pace with documentation demands and evolving standards. Expertise in trace impurity analysis and global regulatory harmonization is now a core competency.

Digital Infrastructure for Compliance

Compliance today requires robust digital systems. U.S. companies are investing heavily in Regulatory Information Management Systems, labeling platforms, and chain-ofcustody repositories to harmonize MoCRA’s federal requirements with state mandates, EPR calculations, and retailer attestations. Without these tools, staying audit-ready and transparent across jurisdictions is nearly impossible.

Reformulation Realities

Reformulation is rarely a simple swap. Removing or restricting an ingredient can prompt cascading changes that affect emulsifiers, preservatives, rheology modifiers, fragrances, UV filters, and pigments. Stability, texture, and performance may all be affected.

Broad ingredient bans force manufacturers to screen alternatives, validate analytical methods, and check for unintended consequences, like microbial stability or oxidation. Sell-through dates and retailer alignment add further complexity. Each change often requires new rounds of stability testing, microbiological checks, compatibility assessments, and, for sun care, photostability programs.

PCPC’s Advocacy

PCPC remains committed to advancing science-based regulation. Our goal is clear: protect consumers, support innovation, and preserve North American competitiveness— so U.S. suppliers, formulators, and brands can deliver safe, effective products without navigating unnecessary regulatory hurdles.