For many years, cosmetic companies primarily focused on federal FDA requirements when evaluating compliance in the United States.
However, the regulatory landscape is evolving.
California is increasingly introducing ingredient restrictions that go beyond federal cosmetic rules, often aligning with substances already restricted or banned in the European Union.
For brands operating internationally, this raises an important question:
Could European restrictions become an early indicator of future US ingredient bans?
California: a growing regulatory driver
California has become one of the most influential regulatory markets in the US cosmetics industry.
Through state-level legislation, California has introduced restrictions on a growing number of cosmetic ingredients considered potentially harmful to human health or the environment.
This trend is particularly important because many brands distribute products nationwide using a single formulation strategy.
As a result, California requirements can quickly influence broader US product decisions.
Lilial: from EU ban to California restriction
One of the clearest examples is Lilial (Butylphenyl Methylpropional).
European Union
Lilial was banned in cosmetic products in the European Union in 2022 following its classification as a CMR substance (Carcinogenic, Mutagenic or Reprotoxic).
California
California has now included Lilial in its expanding list of prohibited cosmetic ingredients, with restrictions expected to apply from January 1, 2027 under Assembly Bill 496 (AB 496).
This illustrates a growing regulatory pattern:
Substances restricted in Europe may later become targets for state-level restrictions in the United States.
Beyond Lilial: a broader regulatory trend
Lilial is unlikely to remain an isolated case.
Several categories of substances already under scrutiny in Europe are also attracting increasing attention in the US, including:
- PFAS
- Certain fragrance allergens
- CMR substances
- Some preservatives and UV filters
- Environmental contaminants
At the same time, consumer expectations around ingredient transparency and safety continue to increase.
Why this matters for cosmetic companies
For brands and manufacturers, these developments create several challenges.
A formulation compliant at the federal US level may still face restrictions in California or other states.
Companies therefore need to:
- Monitor both federal and state-level developments
- Track ingredient status across multiple regions
- Anticipate future reformulation needs
- Review fragrance compositions and raw materials proactively
The cost of waiting until restrictions become enforceable can be significant, particularly for products with complex supply chains or large portfolios.
The growing influence of EU regulations
European cosmetic regulation remains one of the most influential frameworks globally.
Many companies already use EU restrictions as an early warning system when assessing long-term ingredient risks.
While the US regulatory system differs structurally, California’s recent initiatives suggest that certain European regulatory trends may increasingly influence the North American market.
What companies should do now
To reduce future compliance risks, companies should consider:
- Identifying substances already restricted in the EU
- Reviewing products sold in California separately from broader US portfolios
- Strengthening ingredient and supplier monitoring
- Preparing internal reformulation strategies early
Regulatory anticipation is becoming a strategic advantage.
Key takeaway
California is no longer simply following federal cosmetic regulation.
State-level restrictions are becoming increasingly important, and EU ingredient bans may offer valuable insight into future regulatory trends in the US market.
For cosmetic companies, proactive monitoring and early assessment are becoming essential.
Going further
If you need support reviewing ingredient restrictions or anticipating future compliance risks across markets, our regulatory team can assist you.
For many years, cosmetic companies primarily focused on federal FDA requirements when evaluating compliance in the United States.
However, the regulatory landscape is evolving.
California is increasingly introducing ingredient restrictions that go beyond federal cosmetic rules, often aligning with substances already restricted or banned in the European Union.
For brands operating internationally, this raises an important question:
Could European restrictions become an early indicator of future US ingredient bans?
California: a growing regulatory driver
California has become one of the most influential regulatory markets in the US cosmetics industry.
Through state-level legislation, California has introduced restrictions on a growing number of cosmetic ingredients considered potentially harmful to human health or the environment.
This trend is particularly important because many brands distribute products nationwide using a single formulation strategy.
As a result, California requirements can quickly influence broader US product decisions.
Lilial: from EU ban to California restriction
One of the clearest examples is Lilial (Butylphenyl Methylpropional).
European Union
Lilial was banned in cosmetic products in the European Union in 2022 following its classification as a CMR substance (Carcinogenic, Mutagenic or Reprotoxic).
California
California has now included Lilial in its expanding list of prohibited cosmetic ingredients, with restrictions expected to apply from January 1, 2027 under Assembly Bill 496 (AB 496).
This illustrates a growing regulatory pattern:
Substances restricted in Europe may later become targets for state-level restrictions in the United States.
Beyond Lilial: a broader regulatory trend
Lilial is unlikely to remain an isolated case.
Several categories of substances already under scrutiny in Europe are also attracting increasing attention in the US, including:
- PFAS
- Certain fragrance allergens
- CMR substances
- Some preservatives and UV filters
- Environmental contaminants
At the same time, consumer expectations around ingredient transparency and safety continue to increase.
Why this matters for cosmetic companies
For brands and manufacturers, these developments create several challenges.
A formulation compliant at the federal US level may still face restrictions in California or other states.
Companies therefore need to:
- Monitor both federal and state-level developments
- Track ingredient status across multiple regions
- Anticipate future reformulation needs
- Review fragrance compositions and raw materials proactively
The cost of waiting until restrictions become enforceable can be significant, particularly for products with complex supply chains or large portfolios.
The growing influence of EU regulations
European cosmetic regulation remains one of the most influential frameworks globally.
Many companies already use EU restrictions as an early warning system when assessing long-term ingredient risks.
While the US regulatory system differs structurally, California’s recent initiatives suggest that certain European regulatory trends may increasingly influence the North American market.
What companies should do now
To reduce future compliance risks, companies should consider:
- Identifying substances already restricted in the EU
- Reviewing products sold in California separately from broader US portfolios
- Strengthening ingredient and supplier monitoring
- Preparing internal reformulation strategies early
Regulatory anticipation is becoming a strategic advantage.
Key takeaway
California is no longer simply following federal cosmetic regulation.
State-level restrictions are becoming increasingly important, and EU ingredient bans may offer valuable insight into future regulatory trends in the US market.
For cosmetic companies, proactive monitoring and early assessment are becoming essential.
Going further
If you need support reviewing ingredient restrictions or anticipating future compliance risks across markets, our regulatory team can assist you.
