These updates were provided to PPAI’s Product Responsibility Action Group during its August meeting by Karolyn Helda, QIMA, and Rick Brenner, Product Safety Advisors:

United States: Federal

The No Lead in Toys Act (SB 4932) was proposed in June 2026. This is a bipartisan bill to address gaps identified in a report on the Consumer Product Safety Commission by the Government Accountability Office. The law would direct CPSC to implement children’s product safety recommendations issued by the GAO:

  • Establish a plan to oversee compliance with e-filing requirements.
  • Create a process to use violations data to assess risks associated with independent and government laboratories.
  • Review applicable lead requirements.
  • Document a process for remaining up to date on changes relating to phthalates and other toxic substances.


The U.S. Food & Drug Administration has announced action targeting two petroleum-based color food additives that are no longer widely in use. Both actions are part of FDA’s ongoing effort to remove obsolete petroleum-based food color additive authorizations:

  • The final order revoking authorization for Orange B is effective September 8, 2026.
  • Revocation has been proposed for Citrus Red No. 2, but no deadline set until the order becomes final.


LEARN MORE: Attend the PPAI Responsibility Summit, September 14-16 in Denver.

The No PFAS in Cosmetics Act (H.R. 9594) was introduced in July 2026. The bill, which has been referred to committee and has not been enacted, is intended to prohibit the intentional addition of PFAS in cosmetic products sold in the U.S. Cosmetics containing intentionally added PFAS would be considered adulterated under the Federal Food, Drug, and Cosmetic (FD&C) Act.

The Federal Trade Commission recently stepped up its “Made in USA” enforcement following a presidential executive order directing the agency to prioritize the issue, issuing warning letters to seven companies in July. At particular risk are companies that import all components and assemble/finish in the U.S. but claim “Manufactured in USA.”

RELATED: Understanding ‘Made In The USA’ Labeling Rules

In July, CPSC announced plans to change how its National Electronic Injury Surveillance System for emergency room injury reporting operates. Historically, this data has been valuable for product development, development of product safety standards (ASTM, etc.) and expert witness cases. NEISS data is also routinely used to petition the commission and support regulation, and there is concern that changes to the system could undermine that work.

U.S. States

Enforcement of California’s Truth in Recycling law (SB 343) was set to take effect on October 4, 2026, but is currently blocked by court order. This law restricts use of the chasing arrows symbol unless a product is curbside recyclable in California.

ICYMI: Court Presses Pause On California Recycling Label Law

Illinois has enacted the Chemicals in Cosmetic Products Act (Public Act 104-059s45). Compliance is required by July 1, 2028. This new law prohibits the manufacture or sale of cosmetics containing specified intentionally added chemicals:

  • Dibutyl phthalate
  • Diethylhexyl phthalate
  • Formaldehyde
  • Paraformaldehyde
  • Methylene glycol
  • Quaternium-15
  • Mercury
  • Isobutylparaben
  • Isopropylparaben
  • m-Phenylenediamine and its salts
  • o-Phenylenediamine and its salts
  • 13 specific toxic PFAS compounds and their salts


Limited exemptions exist for technically unavoidable trace contaminants.

The New Mexico Environment Department has published new guidance for consumer products with intentionally added PFAS to assist manufacturers in complying with the state’s PFAS Protection Act. The new resource includes PFAS reporting and labeling guidance, downloadable label files, FAQs and access to the New Mexico PFAS Reporting System (aka NMPRS).

Manufacturers can now register for NMPRS accounts. Backend tools are activated for submitting reports, requesting extensions and uploading Currently Unavoidable Use (CUU) proposals.

  • The deadline to submit CUU proposals for Phase 1 products and labeling waiver requests for qualifying products is October 31, 2026.


The New Jersey Legislature passed S1281, a bill that prohibits the sale, manufacture, offer for sale and distribution in New Jersey of apparel and diaper products containing intentionally added PFAS. The bill awaits the governor’s signature to start the countdown to take effect in two years (estimated late summer 2028). Manufacturers must then certify that each covered product does not contain intentionally added PFAS by:

  • Submitting certifications to the Division of Consumer Affairs.
  • Renewing certifications every five years.
  • Submitting updated certifications whenever manufacturing or material changes occur.
  • Providing a copy of certification to any purchaser of the product.


The law will be enforced by the Division of Consumer Affairs, with civil penalties up to $20,000 per violation and up to $25,000 per day for continuing violations.

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European Union

The EU Digital Product Passport Registry is now live (as of July 20, 2026) but still in a “sandbox” mode for businesses to test. The registry provides a secure infrastructure to register unique product identifiers, associated metadata (tariff codes, etc.) and other detailed data (carbon footprint, etc.) held by operator or third-party DPP service providers. Product data is stored in a decentralized manner, but economic operators must register each DPP in the registry.


Australia

Australia enacted a mandatory Consumer Goods (Aquatic Toys) Safety Standard, effective June 26, 2026. A two-year transition period allows suppliers to comply with either the 2020 or 2026 standard until June 26, 2028.

The new standard defines “aquatic toy” as: A toy intended to bear the mass of a child under 14 years of age and be used in play in shallow water by a child. It also strengthens requirements on product scope, warning labels and alignment with two ISO-based safety provisions to help reduce drowning risks:

  • AS/NZS ISO 8124.1, Safety of Toys – Part 1
  • ISO 8124-1, Safety of Toys – Part 1


Products not covered under the new standard: beach balls, surfboards, bodyboards, kickboards, inflatable air beds and larger inflatable boats intended solely for deep-water use.

Product Testing Concerns

The U.S. Federal Communications Commission has voted to move forward with a proposal that would ban all labs located in China and Hong Kong from testing and certifying electronic devices for the U.S. market. The proposal would expand a previous FCC action that only applied to Chinese labs with direct government ties.

  • If adopted, the FCC would no longer accept test results from any China- or Hong Kong-based lab, regardless of ownership.
  • Many currently certified labs will see certifications ending in 2026 and 2027.
  • The change could significantly affect electronics manufacturers by reshaping global product testing, certification and compliance processes.
  • Some companies are exploring FCC testing labs in Japan or outside Asia.
  • Proposed No Lead in Toys Act CPSC lab oversight provisions could further impact China and Hong Kong labs.


Electronics testing is a major risk area for branded products, and they are often inconsistently evaluated. In particular, companies should be mindful of the gap between basic transport testing and true product safety testing for power banks and wireless chargers:

  • Many suppliers rely on testing only for UN 38.3, which is a transportation/shipping standard, rather than a full safety evaluation. This standard does not test the battery management system or the power bank under load (plugged in).
  • This is in contrast with more rigorous testing such as UL 2056, “the gold standard for power banks” – full certification requires a factory audit, annual fee and subcontractor audits. It’s a pricey effort; some factories test to UL 2056 but do not certify, and thus they cannot label the product as UL Listed.

Suppliers that embed electronic components into otherwise non-electronic products face elevated risk without having in-house technical knowledge to evaluate those components properly. This creates an expertise gap at the product-development level. A recommended approach for risk reduction is to go beyond basic testing for things like lead and phthalates by engaging a testing lab for a construction review of product schematics before production.

NEW: Visit the PRAG Update page for detailed information on the latest regulatory developments, including CPSC recalls and other actions, Prop 65 notices, legislative news and much more.