On September 23, 2026, New Zealand's Environmental Protection Authority (EPA) announced that the Government has approved amendments to the Hazardous Substances and New Organisms Act 1996 (the "HSNO Act") to implement restrictions on three new persistent organic pollutants (POPs)—chlorpyrifos, medium-chain chlorinated paraffins (MCCPs), and long-chain perfluorocarboxylic acids, their salts and related compounds (LC-PFCAs)—by including them in Schedules 1AA and 2A of the Act.
Among them, LC-PFCAs have a wide range of applications, and personal care products are covered. The restrictions on LC-PFCAs will take effect on December 16, 2026, and relevant cosmetics companies should pay close attention.
Background of the Amendment
In May 2025, three chemicals mentioned above were listed in the Stockholm Convention. As a party to the Convention, New Zealand fulfills its obligations under the HSNO Act by amending the Hazardous Substances and New Organisms (Schedules 1AA and 2A) Order 2026, which adds the three chemicals to Schedule 2A and amends Schedule 1AA accordingly.
According to the EPA, the restrictions on LC-PFCAs and MCCPs will take effect on December 16, 2026, and that on chlorpyrifos will take effect on July 8, 2027.
LC-PFCAs: PFAS Substances with Carbon Chain Lengths of 9 to 21
LC-PFCAs are members of the per- and polyfluoroalkyl substances (PFAS) chemical class, covering perfluorocarboxylic acids with carbon chain lengths from 9 to 21, their salts, and related compounds.
It should be noted that the definition of LC-PFCAs listed this time excludes perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds—this group of substances was previously listed separately in Annex A of the Stockholm Convention.
Wide Range of Applications, with Personal Care Products Included
According to the EPA discussion document (Amendments to Schedule 2A of Hazardous Substances and New Organisms Act to implement restrictions on three new persistent organic pollutants), LC-PFCAs have an extremely wide range of applications, covering: 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 the automotive industry, among others.
In addition, LC-PFCAs may also be present in certain products and articles as unintentionally produced by-products during the manufacturing processes of other PFAS and in certain industrial processes.
Use and Status of LC-PFCAs in New Zealand
According to the discussion document, there are currently no approvals under Part 5 of the HSNO Act in New Zealand for LC-PFCAs as chemicals in their own right, and the EPA has no information on their current import, manufacture, use or export; LC-PFCAs may have been imported as component chemicals in products covered by an EPA group standard.
None of the LC-PFCAs are listed on the New Zealand Inventory of Chemicals (NZIoC); however, a number of related compounds from the indicative list appear on the NZIoC, indicating that they have been used as components in products approved for import into New Zealand. The EPA stated that it is uncertain whether products or articles containing these chemicals are still being imported into or used in New Zealand, but given the wide range of applications of LC-PFCAs, this appears likely.
Specific Exemptions Do Not Cover Personal Care Products
Annex A of the Stockholm Convention provides specific exemptions for the continued production and use of LC-PFCAs. The continued-use exemptions listed in the discussion document include:
1. Semiconductors designed for replacement parts not covered in the bullets below (applying for five years until December 16, 2031);
2. Semiconductors designed for replacement parts for combustion engine powered vessels (applying until the end of the service life of the articles or 2041, whichever comes earlier);
3. Replacement parts for motor vehicles (covering all land-based vehicles) that have ceased mass production, with applications including semiconductors, coatings, cables, electronics, engines, hydraulic system components and relay assemblies (applying until the end of the service life of the articles or 2041, whichever comes earlier).
It should be noted that none of the above exemptions cover personal care products.
Impact on and Recommendations for Cosmetics Companies
1. Pay attention to the effective date and review formulations: from December 16, 2026, products containing LC-PFCAs (including personal care products) will be prohibited from being imported into New Zealand and from being manufactured or used in New Zealand. Companies exporting cosmetics and ingredients to New Zealand are advised to review whether their formulations contain perfluorocarboxylic acids with carbon chain lengths from 9 to 21, their salts and related compounds (note that PFOA, its salts and related compounds are already regulated separately), confirm each item with raw material suppliers, and adjust formulations in advance where necessary;
2. Plan in a coordinated manner for overlapping PFAS controls: New Zealand's EPA has previously prohibited cosmetics with intentionally added PFAS through the Cosmetic Products Group Standard 2020—from December 31, 2026, the import and manufacture of such cosmetics is prohibited, and from December 31, 2027, their sale and supply is prohibited. As LC-PFCAs belong to the PFAS family, with the addition of this POPs restriction, the compliance room for cosmetics containing such substances will be very limited, and companies are advised to plan timelines for formulation substitution and supply chain switching in a coordinated manner;
3. Follow subsequent implementation documents: the specific exemption arrangements for the three POPs vary from one another (none of which covers personal care products). Companies are advised to keep following New Zealand's subsequent documents on the registration of specific exemptions, articles in use notifications, and the storage and disposal requirements for POPs wastes, and to systematically retain compliance evidence.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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