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

United States: Sunscreen Ingredient Updates

At the federal level, the U.S. Food & Drug Administration has removed two active ingredients removed from the OTC sunscreen monograph, effective September 11, 2027:

  • PABA (para-aminobenzoic acid): linked to allergic contact dermatitis and photoallergic reactions.
  • Trolamine salicylate: anticoagulant properties (salicylate-based, similar to aspirin), risk of increased bleeding.


Companies should review any sunscreen formulas now and reformulate if either ingredient is present.

At the state level, California issued a new sunscreen labeling rule, effective January 1, 2027, that prohibits “reef safe,” “ocean safe,” “marine safe” or similar claims on sunscreens containing any chemical UV filters including, but not limited to:

  • Avobenzone
  • Homosalate
  • Octinoxate
  • Octisalate
  • Octocrylene
  • Oxybenzone


U.S. States

A committee of the New Jersey Assembly is considering a bill (A5452 – Protecting Against Microplastics Act) introduced in mid-September that defines microplastics as polymer materials 5mm or less in diameter and would apply new regulation for specified products with intentionally added or secondary microplastics. Key provisions include:

  • Exterior product labeling required for cleaning, cosmetic, foodware or potentially ingestible products containing intentionally added microplastics or capable of generating secondary microplastics.
  • After two years, on-product labeling will be required for products that come into contact with food, foodstuffs or beverages (“This product contains microplastics” in English and Spanish).
  • After three years, sales would be prohibited for covered cleaning, cosmetic and potentially ingestible products containing intentionally added microplastics or capable of generating secondary microplastics.
  • Prohibits “microplastic-free” claims where intentionally added microplastics are present.


A federal court issued a preliminary injunction preventing New Mexico from enforcing its PFAS product-labeling requirement (Erlenmeyer flask symbol) while litigation proceeds, but phased PFAS sales bans and reporting obligations remain in effect.

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California Prop 65 Strategy

Of nearly 1,000 chemicals listed under Prop 65, lawsuits concentrate around about 20 substances, and roughly two-thirds involve just lead and phthalates.

Companies can use the state’s Prop 65 Notice of Violation data (access the 60-Day Notice Search here) as a leading indicator of which chemicals “bounty hunters” (citizen enforcers and plaintiffs’ attorneys) are targeting. Settlement agreements name specific chemicals of concern and provide a testing framework, but it’s important to remember that those agreements and the limits they enumerate are only binding to the signatory parties.

The state’s new short-form and long-form warning requirements (effective January 1, 2025, with mandatory full compliance required by January 1, 2028) mandate naming a specific chemical on labels. Generic labels to cover the potential presence of any listed substance are no longer sufficient.

New U.S. Fiber Designation

The Federal Trade Commission has issued a temporary designation for renoa, a new USA-made fiber developed in New York City and regenerated from keratin-rich textile offcuts and waste.

While the final FTC order is pending, if confirmed, this will be the first new generic fiber classification approved by the FTC since polylactic acid/PLA in 2002, and it would enable brands to legally identify renoa by name on U.S. textile labels. According to Everbloom, the company that developed it, renoa:

  • Uses 99% less water than silk production, 50% less than cashmere production and 30% less than wool production.
  • Generates up to 92% fewer greenhouse gas emissions than bio-recycled polyester, silk, cashmere and wool.


ICYMI: FTC Approves First New Apparel Fiber Classification In Nearly 25 Years

CPSC Update

Button/coin batteries and magnets continue to pose significant recall risks for the branded merchandise industry. Both continue to appear in recalls due to non-compliance with existing battery-safety requirements such as Reese’s Law and UL standards. In recent examples, the CPSC worked with importers to recall refrigerator magnets and light-up children’s toys have been recalled due to ingestion hazards. Water beads are another ingestion risk, with one recent squishy toy recall highlighting the need for particular vigilance with the current popularity of such toys.

On September 28, the U.S. Consumer Product Commission named Colette Devine as its first-ever chief enforcement officer (replacing the prior director of compliance role). As chief enforcement officer, Devine will lead CPSC’s Office of Compliance and Field Operations and oversee the agency’s continued efforts to enforce federal product safety laws.

According to an agency press release, Devine brings more than 20 years of experience in compliance, investigations, risk management and regulatory governance across multinational operations spanning 28 countries.

  • From an industry perspective, the appointment and new title signals a heavier enforcement focus for the CPSC, which has not confirmed a start date for Devine as of this article’s publication.
  • In 2025, the agency announced 542 recalls and product safety warnings, the highest annual total in its history.


“CPSC has dramatically stepped up its enforcement efforts, and Colette is the right person to help us build on that progress,” said CPSC Acting Chairman Peter A. Feldman in the release. “American consumers are increasingly confronted with dangerous and non-compliant products from overseas, particularly through online marketplaces. This new title reflects the stronger role we expect this office to play in meeting that challenge.”

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.

European Regulatory Updates

The European Union has updated its Persistent Organic Pollutants (POPs) Regulation (EU) 2019/1021 to include:

The EU also proposed amendments to its Toy Safety Directive that would:

  • Prohibit Lilial as an allergenic fragrance in toys and remove it from the fragrance-labeling list.
  • Reduce the Bisphenol A migration limit from 0.04 mg/l to 0.005 mg/l for toys intended for children under 36 months or intended to be placed in the mouth.


Sweden has proposed national PFAS restrictions on clothing, footwear, cosmetics, food contact utensils and ski wax, following similar measures in France and Denmark. If approved, the rule would be enforceable on January 1, 2028, but repealed should EU-wide legislation (likely) take effect. Proposed exemptions include certain recycled-content clothing, PPE and products already in use.

Canada Updates

Environment & Climate Change Canada issued two Section 71 notices on August 29 requiring qualifying Canadian manufacturers, importers and users to provide information on 200 priority substances. This requirement parallels the 2025 federal PFAS reporting experience but is expected to be more complex, given the volume of chemicals covered. Affected product categories include (but are not limited to) toys, children’s products, apparel, textiles and food contact items (see Section 3.1.1 of the ECCC guidance for the full list of 10 product categories).

  • Phase 1 covers 184 substances, with reporting due March 3, 2027.
  • Phase 2 covers 16 substances, with reporting due September 8, 2027.


Importers may need to report substances in imported products when applicable thresholds are exceeded. Foreign suppliers are not directly subject but may receive supply chain inquiries from Canadian customers.

In September, Health Canada issued a button/coin cell battery safety notice that the agency considers non-compliant products containing button or coin batteries to present an ingestion hazard. Health Canada may take immediate compliance and enforcement action against dangerous products.

  • Products must meet applicable requirements under standards including ANSI/UL 4200A-23 and ASTM F963-23, or equivalent standards.
  • Packaging and labeling must meet applicable child-resistance, battery-safety and warning requirements.
  • Consult UL 4200A (general products) or ASTM F963 (toys) standards to assist in compliance.


New Zealand Sand/Asbestos Toys Proposal

New Zealand is proposing an unsafe goods notice for toys and craft products containing sand due to potential asbestos contamination risk. The proposed notice covers sand-filled toys, sand art kits and decorative craft products. If adopted, suppliers must provide a test report dated within one year confirming no asbestos, per ISO 22262, from an accredited lab.


New China Laws Pose Supply Chain Due Diligence Risk

China issued two decrees in April – State Council Decrees No. 834 and 835 – as a legal framework designed to protect the country’s domestic supply chains and counter foreign sanctions or extraterritorial laws. This includes prohibiting the recognition or enforcement of certain U.S. sanctions targeting Chinese companies, creating tension with global due diligence obligations such as the U.S. UFLPA and other fair labor laws, as well as factory audits and similar efforts.