Not Legal Advice
This page summarises publicly reported regulatory developments for general awareness. Requirements vary by product, ingredient, and target market, and regulations change — always confirm current requirements with a qualified regulatory professional before launch.
✛ United States
MoCRA: Ongoing Implementation, Not a New Law
The Modernization of Cosmetics Regulation Act (MoCRA) continues to phase in since its 2022 passage. Facility registration and product listing with the FDA are already required for most manufacturers. Reported developments for 2026 include continued delays to the proposed fragrance allergen labelling rule (most recently anticipated around mid-2026) and the cosmetic GMP rule, which has reportedly moved to FDA's longer-term action list rather than a near-term deadline. FDA has also been reported to be increasing public transparency around adverse event data for cosmetic products.
- Facility registration & product listing — already in effect for most manufacturers
- Safety substantiation documentation — expected to be maintained on an ongoing basis
- Fragrance allergen labelling rule — proposed rule timeline reportedly pushed to 2026
- Cosmetic GMP rule — reportedly delayed, no near-term date confirmed
✛ European Union
EU: Tightening Ingredient & Packaging Rules
The EU Cosmetics Regulation (EC No 1223/2009) continues to evolve through Annex updates. Reported 2026 developments include new fragrance allergen labelling requirements, continued phase-out timelines for certain PFAS substances under REACH, and packaging-related obligations connected to the EU's packaging and packaging waste framework (PPWR). Brands selling into the EU should expect ingredient restriction lists and labelling obligations to keep shifting.
- Fragrance allergen labelling — expanded list of substances requiring individual disclosure
- PFAS phase-out — transitional arrangements under REACH continuing to wind down
- REACH SVHC list — periodically updated with newly classified substances of concern
- PPWR (packaging waste regulation) — introducing new packaging-related obligations over time
✛ ASEAN & Asia Pacific
ASEAN Cosmetic Directive: Ongoing Ingredient Annex Updates
Regulators across the ASEAN region periodically update ingredient annexes under the ASEAN Cosmetic Directive (ACD), with individual countries (such as Malaysia's NPRA) issuing corresponding local guideline updates. Neighbouring markets including South Korea and Japan have also reported proposed updates to safety standards and raw material sourcing rules. For brands manufacturing in or exporting from Singapore, staying aligned with both ACD updates and destination-market rules (FDA, EU, or others) is an ongoing compliance task rather than a one-time check.
✛ What This Means for Your Launch
Practical Takeaways
Document Early
Build safety substantiation and compliance documentation into your formulation timeline, not as a final step.
Review Fragrance Composition
Full fragrance allergen data is increasingly required — generic "parfum" labelling is losing ground globally.
Factor In Packaging Rules
Packaging compliance (recyclability, material disclosure) is becoming as relevant as ingredient compliance.
Confirm Per Market
Compliance requirements are market-specific — confirm for each country you plan to sell into.
Planning a Launch in a New Market?
Talk to our team about compliance support for your target markets before you finalise your formulation.
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