On July 10, 2026, the Governor of Illinois signed the Chemicals in Cosmetic Products Act (HB 3409) into law, prohibiting the manufacture, sale, delivery, holding, or offering for sale of cosmetic products containing 24 specific “intentionally added” ingredients, effective July 1, 2028.
Background
In recent years, in addition to the federal Modernization of Cosmetics Regulation Act (MoCRA, 2022), various US states have successively enacted cosmetic ingredient bans and restrictions. Illinois' Chemicals in Cosmetic Products Act was passed by the 104th General Assembly (HB 3409) and is intended to reduce hazardous chemicals in cosmetics associated with cancer, reproductive harm, and other health risks.
Key Contents
1. Prohibition of 24 “Intentionally Added” Ingredients (Section 15(a))
The following 24 substances (11 named chemicals + 13 PFAS and their salts), when used as “intentionally added” ingredients in cosmetics, are prohibited. The complete list and CAS numbers are as follows:
| Substance | CAS No. |
| Dibutyl phthalate (DBP) | 84-74-2 |
| Diethylhexyl phthalate (DEHP) | 117-81-7 |
| Formaldehyde | 50-00-0 |
| Paraformaldehyde | 30525-89-4 |
| Methylene glycol | 463-57-0 |
| Quaternium-15 | 51229-78-8 |
| Mercury | 7439-97-6 |
| Isobutylparaben | 4247-02-3 |
| Isopropylparaben | 4191-73-5 |
| m-Phenylenediamine and its salts | 108-45-2 |
| o-Phenylenediamine and its salts | 95-54-5 |
| Perfluorooctane sulfonate (PFOS) | 1763-23-1 |
| Potassium perfluorooctanesulfonate | 2795-39-3 |
| Diethanolamine perfluorooctane sulfonate | 70225-14-8 |
| Ammonium perfluorooctane sulfonate | 29081-56-9 |
| Lithium perfluorooctane sulfonate | 29457-72-5 |
| Perfluorooctanoic acid (PFOA) | 335-67-1 |
| Ammonium pentadecafluorooctanoate | 3825-26-1 |
| Nonadecafluorodecanoic acid | 335-76-2 |
| Ammonium nonadecafluorodecanoate | 3108-42-7 |
| Sodium nonadecafluorodecanoate | 3830-45-3 |
| Perfluorononanoic acid (PFNA) | 375-95-1 |
| Sodium heptadecafluorononanoate | 21049-39-8 |
| Ammonium perfluorononanoate | 4149-60-4 |
2. Scope and Trace Quantity Exemption (Sections 10, 15(b))
“Cosmetic product” covers makeup, hair products, nail products, soaps and lotions, tanning products, and perfumes and eau de cologne, and incorporates the definition of “cosmetic” under the US Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321). Additionally, where a product is manufactured through a process intended to comply with this Act and contains a “technically unavoidable trace quantity” of a listed ingredient solely due to impurities of raw materials, the manufacturing process, storage, or packaging, it is not deemed a violation.
3. Effective Date (Section 99)
This Act takes effect on July 1, 2028, providing the industry with approximately a two-year transition period for formulation adjustment and compliance.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Our Services
- The United States Agent
- The United States FDA Cosmetic Facility Registration
- The United States FDA Cosmetic Product Listing
- The United States FDA OTC Drug Registration
- The United States Color Additive Batch Certification
- The United States Cosmetic/OTC Drug Labeling Review
- International Cosmetic Ingredient Name (INCI) Application
Further information:
