Why January 2026 Matters for Product Review
January 2026 represents a regulatory decision point, rather than a legislative reset. While few cosmetic regulations commence exactly on 1 January, several formally adopted measures, classification changes and enforcement expectations now require immediate consideration during product review, safety assessment and compliance sign-off.
For regulatory-led organisations reviewing formulations, labels and technical files, January marks the point at which “future” regulatory changes must now be treated as active constraints within product compliance decisions.
Regulatory Update – January Status
Amendments to the UK’s retained Cosmetics Regulation, adopted in late 2025, are now confirmed to apply from 2026, with transitional provisions in force. From January 2026, newly prohibited substances classified as CMR under GB CLP must be treated as non-compliant for any new product placements. At the same time, revised formaldehyde-release labelling thresholds must be taken into account during label and CPSR reviews, even where sell-through provisions may still apply. In addition, UV filters removed from the permitted list, including 4-MBC, are definitively excluded from all new placements on the GB market.
Why Does It Matter for Product Review?
- Regulatory assessments conducted from January 2026 cannot rely on pre-2025 ingredient acceptability.
CPSRs signed after this point must clearly distinguish:
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- Products already placed on the GB market (eligible for transitional sell-through)
- Products considered “new placements” under the updated regulatory position
- Products already placed on the GB market (eligible for transitional sell-through)
Application / Impacted Products
- Nail systems, hair treatments, preservative-containing products, fragranced formulations and UV-exposed cosmetics.
Any formulation containing:
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- Formaldehyde-releasing substances
- Substances with updated GB CMR classifications
- UV filters subject to GB divergence from EU allowances
- Formaldehyde-releasing substances
Regulatory Update – January Adoption
In January 2026, the European Commission formally adopted an amendment to Regulation (EC) No 1223/2009 strengthening controls on substances classified as CMR. While the substantive application dates occur later in 2026, the position is legally certain as of the date of adoption.
Why Does It Matter for Product Review?
From January 2026 onwards:
- Ingredient status is no longer uncertain or “pending”
- Safety assessments must reflect the adopted regulatory outcome, not historical use
CPSRs, reformulation decisions and portfolio planning must treat affected substances as phasing out, even where sell-through remains possible.
Application / Impacted Products
Broad relevance across cosmetic categories, with heightened impact on:
- Hair dyes and bleaching systems
- Nail adhesives and hardeners
- UV protection products
- Colour cosmetics using complex organic ingredients
Regulatory Update – MoCRA Enforcement Phase
As of January 2026, the Modernization of Cosmetics Regulation Act (MoCRA) has moved beyond its initial implementation phase. FDA oversight now reflects an expectation of routine, full compliance rather than transitional flexibility.
Why Does It Matter for Product Review?
Product compliance reviews must now assume that:
- Safety substantiation may be requested at any time
- Serious adverse event reporting systems must already be operational
- Facility registration and product listing data must be accurate and current
January marks a shift from policy interpretation to compliance verification.
Application / Impacted Products
- All cosmetics marketed in the US.
Increased regulatory sensitivity for:
- Leave-on products
- Products used by vulnerable populations
- Products with complex or novel ingredient profiles
Regulatory Update – Ongoing Enforcement
No new cosmetic regulation formally enters into force in January 2026. However, the month represents a compliance continuity checkpoint under the existing Canadian Cosmetic Regulations, reinforcing the expectation of ongoing adherence rather than introducing new legal obligations.
Why Does It Matter for Product Review?
- Cosmetic Notification Forms (CNFs) continue to be actively enforced.
- Increased regulatory attention on environmentally persistent substances means ingredient acceptability must be assessed conservatively.
Application / Impacted Products
- Products containing fluorinated substances, specialty polymers or environmentally persistent chemistries.
- Products newly entering or re-entering the Canadian market in 2026.
January 2026 – Cross-Market Compliance Implications
For regulatory-led product review, January 2026 requires:
- Treating adopted but not-yet-applicable restrictions as active constraints in formulation decisions
- Ensuring CPSRs, labels and compliance opinions reflect the most current legal position
- Distinguishing clearly between:
- New placements
- Transitional sell-through products
- New placements
- Recognising that enforcement intensity (particularly in the US and UK) has materially increased
Regulatory Review
January 2026 marks a point at which regulatory uncertainty has narrowed. For many substances and product categories, the direction of travel is now fixed, even where transitional timelines apply. Regulatory product review must therefore move beyond historical acceptability and incorporate forward-looking compliance judgement.
ADSL supports regulatory-led organisations through:
- Ingredient and formulation risk assessment against adopted regulatory changes
- CPSR and safety substantiation aligned to current and forthcoming requirements
- Label and compliance review reflecting jurisdiction-specific thresholds
- Strategic reformulation support where ingredient phase-out is required
ADSL – Advanced Development & Safety Laboratories
Technical Team | Paignton, UK
