Date: 7 August 2026

Prepared for: Importers, Manufacturers, Suppliers and Buyers of Cosmetic Products for the Illinois Market

Regulatory Update: Illinois Enacts Ban on 24 Cosmetic Ingredients, Effective July 2028

On 10 July 2026, the Governor of Illinois signed the Chemicals in Cosmetic Products Act (HB 3409) into law, establishing a significant state-level restriction on cosmetic ingredients. From 1 July 2028, it will be unlawful to manufacture, sell, deliver, hold, or offer for sale in Illinois any cosmetic product containing any of 24 specified intentionally added ingredients.

If your product portfolio includes cosmetics distributed in Illinois – whether through traditional retail or e-commerce channels – this law directly affects you.

Background:  

The Act reflects a growing trend of state-level cosmetic ingredient regulation in the United States, complementing the federal Modernization of Cosmetics Regulation Act (MoCRA) of 2022. Its purpose is to reduce consumer exposure to hazardous chemicals associated with cancer, reproductive harm, and other health risks.

 "Cosmetic product" means a substance or mixture that is intended to be applied to the human body to clean, change its appearance, or protect it. It includes makeup, hair products, nail products, soaps and lotions, tanning products, and perfumes and eau de cologne. The definition of "cosmetic product" incorporates the federal definition under the US Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321)

Exemption：

A product is not considered a violation if it:

1. Was manufactured through a process intended to comply with the Act; and

2. Contains only a technically unavoidable trace quantity of a listed ingredient resulting from an impurity of a natural or synthetic ingredient, the manufacturing process, storage or packaging.

Prohibited Ingredients

The Act prohibits the intentional addition of the following 24 substances:

1. 11 Named Chemicals:

2. 13 per- and polyfluoroalkyl substances (PFAS) and their Salts:

It is important to note that this is a prohibition on the 13 PFAS substances expressly identified in the Act, rather than a blanket ban on all PFAS. Illinois is one of several US states to have enacted restrictions on PFAS in cosmetics and several other US states have enacted broader PFAS bans in cosmetics, with effective dates ranging from 2025 to 2028. The table below summarises the current landscape:

 Timeline:  

The law was signed on 10 July 2026, providing the industry with approximately two years for formulation adjustment and compliance.

What this means for you

If your business supplies cosmetic products to the Illinois market whether as a manufacturer, brand owner, importer, distributor, retailer, or e-commerce platform,  the following actions are relevant to your planning:

1. Screen your formulations and raw materials against the 24 listed chemical names and CAS numbers to identify whether any prohibited substances are present.

2. Confirm whether regulated substances are intentionally added, including through raw material mixtures, and obtain supplier documentation on composition, impurities and residuals.

3. Assess trace quantities separately and document your basis for claiming the statutory exemption. The Act sets no numerical threshold, so you must be able to show both the origin of the trace amount and the steps taken to comply.

4. Identify products requiring reformulation and allow adequate time for safety, stability and performance testing.

5. Review inventory and distribution, including e-commerce sales into Illinois, well before the 1 July 2028 deadline.

6. Monitor other state cosmetic laws, as restrictions vary and several states have enacted or are considering similar bans.

Key point to understand: 

MoCRA compliance does not equal Illinois compliance. This is a state specific ban with its own criteria, independent of federal rules. A MoCRA compliant formulation is a useful starting point, but you must still verify it against the Illinois list. With multiple states moving on cosmetic restrictions at different paces and with different lists, state level compliance should be treated as a separate workstream in your regulatory planning.

For further information, the full text of HB 3409 is readable on the Illinois General Assembly website. Should you require support with your regulatory compliance for the US market, please do not hesitate to contact us.

Reference: Illinois HB 3409 – Chemicals in Cosmetic Products Act (Public Act 104-0545)

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