US Tightens the Screw: California Bans 30 Cosmetic Ingredients From 1 Jan 2027, No Sell-Through — And It Binds the Manufacturer

A hard date with no grace period

California's Toxic-Free Cosmetics Act prohibits 30 listed intentionally added ingredients in cosmetics from 1 January 2027. Because 'manufacture' and 'hold' are both prohibited, a California facility is caught even for out-of-state orders, and there is no sell-through period - inventory made before the date cannot be cleared through the state afterward.

Washington is moving in step

Washington's Toxic-Free Cosmetics Act also restricts a list of chemicals in cosmetics and personal-care products, with phase-in timelines that put several of the same substances on a 2027 to 2028 path. Brands selling into both states must treat the two rulebooks as one combined compliance surface.

MoCRA is the backdrop, not the ceiling

MoCRA facility registrations renew every two years (first renewals fell due in 2026), adverse-event reporting is 15 days, and there is still no federal cosmetic GMP rule and no FDA approval for cosmetics. The states are filling the gap with their own ingredient bans - and the FDA issues no certificate proving a factory is registered, so due diligence shifts to the manufacturer.

Why this matters for OEM / private label

When a ban "binds the manufacturer," the factory - not the label - owns the reformulation and documentation burden. Private-label brands that picked a formula without checking the 2027 lists now face rework or withdrawal. QuickOEM's certified network screens formulations against US state bans, MoCRA and EU CPNP so a US-bound line launches clean, not recalled.