The State of Illinois has enacted new legislation restricting the use of certain chemical ingredients in cosmetic products. The Chemicals in Cosmetic Products Act (HB 3409) prohibits cosmetic products containing 24 specified intentionally added substances.
Signed by the Governor of Illinois on 10 July 2026, the Act will become effective on 1 July 2028. Cosmetic manufacturers and companies placing products on the Illinois market will therefore need to review their formulations and supply chains before the compliance deadline.
What Is the Purpose of the Illinois Cosmetics Law?
The Illinois Chemicals in Cosmetic Products Act forms part of a broader regulatory trend in the United States toward stronger oversight of cosmetic ingredients at both federal and state level.
The legislation is intended to reduce consumer exposure to substances associated with cancer, reproductive toxicity and other potential health concerns. It specifically targets chemicals that are intentionally added to cosmetic products during formulation.
Which Cosmetic Ingredients Are Banned in Illinois?
HB 3409 covers a total of 24 chemicals and chemical groups. The list consists of 11 specifically named substances and 13 identified PFAS compounds and their salts.
The specifically listed prohibited ingredients include:
- Dibutyl phthalate (DBP)
- Diethylhexyl phthalate (DEHP)
- Formaldehyde
- Paraformaldehyde
- Methylene glycol
- Quaternium-15
- Mercury
- Isobutylparaben
- Isopropylparaben
- m-Phenylenediamine and its salts
- o-Phenylenediamine and its salts
The prohibition also covers 13 PFAS compounds, together with their relevant salts.
PFAS, or per- and polyfluoroalkyl substances, have become an increasing focus of regulatory action due to their environmental persistence and potential effects on human health.
Which Cosmetic Products Are Covered?
The Illinois Chemicals in Cosmetic Products Act applies to a broad range of cosmetic products, including:
- Makeup products
- Hair care and hairstyling products
- Nail products
- Soaps
- Lotions
- Tanning products
- Perfumes
- Eau de cologne products
Under the Act, a person will be prohibited from knowingly manufacturing, selling, delivering, holding for sale or offering for sale a cosmetic product containing one or more of the listed intentionally added ingredients.
Exemption for Technically Unavoidable Trace Quantities
The legislation includes a limited exemption for cosmetic products containing technically unavoidable trace quantities of a prohibited ingredient.
This exemption may apply when trace quantities result from:
- Impurities in natural or synthetic raw materials
- The manufacturing process
- Storage conditions
- Packaging materials
- Technically unavoidable contamination during production or distribution
For the exemption to apply, the cosmetic product must have been manufactured with the intention of complying with the Act, and the prohibited substance must not have been intentionally added to the formulation.
Transition Period for Cosmetic Manufacturers
As the requirements will become enforceable on 1 July 2028, the cosmetics industry has an approximately two-year transition period to prepare for compliance.
During this period, manufacturers and brands supplying cosmetic products in Illinois should:
- Review existing cosmetic formulations
- Identify prohibited substances and listed PFAS compounds
- Request updated ingredient information from raw material suppliers
- Complete any necessary reformulation activities
- Update technical documentation and supplier declarations
- Assess potential contamination from manufacturing and packaging
- Confirm product compliance before the July 2028 deadline
Companies marketing cosmetics in multiple US states should also consider the growing differences between state-level ingredient restrictions and federal cosmetic requirements.
State-Level Cosmetics Regulation Is Expanding in the US
The Illinois law is one of the latest state-level measures targeting PFAS, formaldehyde, phthalates, parabens and other chemicals of concern in cosmetic products.
As individual states continue to introduce their own prohibited ingredient lists, disclosure requirements and compliance deadlines, companies operating in the US cosmetics market are facing an increasingly complex regulatory environment.
Cosmetic manufacturers should therefore assess their products not only against federal requirements but also against the legislation applicable in each state where their products are marketed.
Under the Illinois Chemicals in Cosmetic Products Act, cosmetic products containing 11 specifically named chemicals and 13 listed PFAS compounds or their salts as intentionally added ingredients will be prohibited.
The requirements will take effect on 1 July 2028, creating important compliance obligations for cosmetic manufacturers, brands, distributors and other companies supplying products in Illinois.
Businesses should use the transition period to review product formulations, raw material documentation and supplier declarations, and to complete any necessary reformulation measures before the legislation becomes enforceable.