Global Cosmetics Regulatory Updates: September 2026 Roundup

North America: U.S. Sunscreen and Cosmetics Requirements

United States

FDA removes PABA and trolamine salicylate from the sunscreen monograph

The FDA's final administrative order OTC000008–1, dated September 11, 2026, removes aminobenzoic acid (PABA) and trolamine salicylate from OTC Monograph M020.

The order takes effect on September 11, 2027, subject to applicable statutory dispute procedures. After that date, sunscreens containing either ingredient will require an approved drug application to be legally marketed. Other proposed sunscreen monograph changes remain separate regulatory actions.

Washington revises its interim lead policy

Washington updated its interim policy on lead in cosmetics, effective August 31, 2026. The statutory 1 ppm limit remains the baseline; qualifying products may follow alternative compliance pathways:

• 2 ppm: general cosmetics.

• 5 ppm: color cosmetics and clay masks.

• 5–10 ppm: qualifying color cosmetics and clay masks, subject to additional batch monitoring, third-party total-lead testing and data requirements.

The policy no longer expires on December 31, 2026. It remains in place until superseded by an adopted rule or rescinded. Companies must confirm eligibility and reporting conditions before relying on it.

Asia: Halal Certification, Imports and Product Claims

Indonesia

Mandatory halal certification proceeds on October 18

The Halal Product Assurance Organizing Agency (BPJPH) confirmed that the certification phase covering cosmetics will proceed on October 18, 2026, without postponement. Overseas suppliers should confirm product classification, the applicable certification or foreign-certificate registration route, and any relevant exemptions. See BPJPH's implementation announcement.

REACH24H's Indonesia BPJPH halal certification services support pathway assessment, material review, application preparation and certification readiness.

EXIM replaces e-BPOM for new applications

From September 1, 2026, new applications for the relevant BPOM import and export services must use EXIM. Supplementary submissions and amendments for applications already filed through e-BPOM remain in the existing system.

Pre-shipment halal verification adds a documentation requirement

BPJPH Regulation No. 4 of 2026 took effect on September 9, 2026. For imports within its scope, verification takes place in the exporting country and/or country of origin, and importers submit the Halal Product Assurance Report (LPPH) for customs purposes.

On September 10, four organizations passed documentary qualification review: PT Sucofindo, PT Surveyor Indonesia, PT Anindya Wiraputra Konsult and PT Mutu Agung Lestari Tbk. Documentary qualification should not be described as completion of every authorization stage.

Future exemptions and draft rules require separate assessment

BPJPH Decree No. 301 of 2026 establishes an exemption list effective March 1, 2027. An exempt material does not automatically exempt a finished cosmetic product.

Other developments remain proposals:

• Nonclinical testing: BPOM's draft addresses electronic applications, technical documentation, supervision and reporting. Comments are due October 16, 2026.

• Processing services: draft halal guidelines address material verification, segregation, shared facilities and records.

Thailand

Thai FDA clarifies whitening and anti-acne claims

Thai FDA guidance addresses ingredients, notification and claims for whitening and anti-acne cosmetics. Claims must be scientifically supported, clear and non-misleading, and must remain within the cosmetic category.

Companies should review labels and advertising for therapeutic implications or claims that products alter natural skin characteristics beyond the permitted cosmetic scope.

Vietnam

Updated GMP guidance applies to domestic manufacturers

Consolidated Document No. 18/VBHN-QD-BYT, issued on September 26, 2026, sets out ASEAN Cosmetic GMP guidance for domestic manufacturing facilities, including applications, inspections and certification administered by the Drug Administration of Vietnam (DAV).

Apostille procedures affect market-access documents

Decree No. 293/2026/ND-CP took effect on September 11, 2026. Companies should assess whether certificates of free sale and letters of authorization qualify for apostille treatment under the applicable convention or bilateral arrangements. Documents outside the applicable scope may still require consular legalization.

South Korea

New legislation supports cosmetics industry development

The Cosmetics Industry Promotion and Support Act and amendments to the Cosmetics Act were promulgated on September 15, 2026, and take effect on September 16, 2027.

The framework introduces certification for innovative cosmetics companies, valid for three years, alongside industry-support measures and a five-year development plan.

Separately, the Ministry of Food and Drug Safety (MFDS) and BPJPH signed a memorandum of understanding on September 18, 2026 covering halal cooperation, information exchange and technical collaboration. The agreement does not itself establish automatic recognition of halal certificates.

Oceania: Ingredient Restrictions and Consultations

Australia

Poisons Standard proposals address several substances

A consultation issued on September 11, 2026 covers acetophenone, vitamin A and silanes that release methyl ethyl ketoxime (MEKO).

Proposed vitamin A limits include:

• 0.05% retinol equivalents (RE) in body lotions.

• 0.3% RE in other topical products.

Comments are due October 12, 2026, ahead of the November committee meeting. These limits remain proposals.

A separate TGA consultation on 4-methylbenzylidene camphor (4-MBC) considers additional restrictions on the sunscreen ingredient, including concentration reduction or prohibition options. Comments are also due October 12, 2026; the consultation does not itself impose a ban.

New Zealand

Long-chain PFCA restrictions take effect in December

Restrictions on long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds take effect on December 16, 2026.

The measures generally prohibit import, manufacture and use, subject to registered exemptions. Existing articles may remain in use until disposal, with applicable disposal or destruction requirements. These measures should not be described as a blanket ban on all PFAS.

Impact and Actionable Advice

International brands, manufacturers and exporters should prioritize five actions:

• Screen formulations: identify PABA, trolamine salicylate, lead contamination and relevant PFAS; assess Australian proposals separately from adopted restrictions.

• Coordinate Indonesia market access: treat halal certification, foreign-certificate registration, pre-shipment verification and BPOM import applications as distinct processes.

• Review claims and documents: reassess Thai whitening and anti-acne claims and confirm document-authentication requirements for Vietnam.

• Check facility-level applicability: distinguish Vietnam's domestic manufacturing obligations from requirements affecting imported finished products.

• Track regulatory status: maintain separate schedules for effective requirements, future deadlines, exemptions and consultation periods.

Companies supplying the U.S. market can also consult REACH24H's U.S. cosmetics compliance services for federal and state regulatory support.