In March, the New Zealand Environmental Protection Authority (EPA) has launched a public consultation seeking industry and stakeholder feedback on proposed restrictions for long-chain perfluorocarboxylic acids (LC-PFCAs)-a subgroup of per- and polyfluoroalkyl substances (PFAS)-commonly used in personal care products and cosmetics. The consultation closes on April 17, 2026.
Background
The proposal stems from New Zealand's obligations under the Stockholm Convention on Persistent Organic Pollutants, an international treaty designed to eliminate or restrict the production and use of highly toxic, persistent chemicals that bioaccumulate in the environment and human body.
In May 2025, chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids, their salts and related compounds (LC-PFCAs) were added to the Stockholm Convention. This is an international treaty to eliminate or restrict the production and use of POPs-highly toxic chemicals that do not readily degrade:
- Chlorpyrifos is an organophosphate pesticide used as a broad-spectrum insecticide in a range of agricultural crops and for biosecurity purposes.
- MCCPs are a complex group of chemicals widely used as plasticisers in polyvinyl chloride (PVC), additives in metalworking fluids, and in paints, sealants, and adhesives.
- LC-PFCAs are a group of long-chain per- and polyfluoroalkyl substances (PFAS), used in a range of applications including in medical and laboratory devices, photo-imaging, food contact materials, paints and surface coatings, fire-fighting foams, textiles and apparel, personal care products, and cleaning agents.
LC-PFCAs in Personal Care Products
According to the EPA's discussion document, LC-PFCAs are members of the PFAS chemical class—often referred to as "forever chemicals" due to their extreme persistence in the environment and human body.
The document explicitly states that LC-PFCAs are used in a wide range of applications, including: industrial uses; electronic articles, medical and laboratory devices; photo-imaging; inks; food contact materials; paints, coatings and varnishes (including those applied to building and construction materials); fire-fighting foams; textiles and apparel; personal care products; cleaning and washing agents; ski waxes; and in the automotive industry.
Proposed Restrictions
The EPA proposes to include LC-PFCAs in Schedule 2A of the Hazardous Substances and New Organisms Act, which would:
- Prohibit the import, manufacture, and use of LC-PFCAs in New Zealand;
- Require environmentally sound disposal of existing stockpiles and products containing LC-PFCAs;
- Allow limited specific exemptions for certain applications (primarily semiconductors and replacement parts for motor vehicles that have ceased mass production).
The Stockholm Convention decisions for these chemicals allow some exemptions that may be relevant for New Zealand. Specific exemptions are time-limited exemptions for specific uses.Unless otherwise stated, these specific exemptions apply for five years. That is, until 16 December 2031. However, no specific exemptions are proposed for continued use in personal care products or cosmetics.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Our Global Compliance Services
[Regulatory Compliance Services]
- China: Compliance Consulting for Cosmetics and Ingredients
- International: Compliance Consulting for Cosmetics (EU, US, Japan, South Korea, Australia & New Zealand, ASEAN, Middle East, Mexico, Brazil, Africa)
- China and International Compliance Consulting for Disinfectants and Household Products
[Data Services]
- China: Cosmetics and Ingredients Data Services (China CosIng)
- International: Cosmetics and Ingredients Data Services covering China (including Taiwan, China), EU, North America, ASEAN, Japan, and South Korea (Global CosIng)
[Product Testing Services]
- Cosmetic Safety and Human Efficacy Testing
- Toxicological Safety Assessment for Cosmetic Ingredients
- In Vitro Efficacy Testing for Cosmetics and Ingredients
Further Information:
