Illinois to Ban Certain Cosmetic Ingredients Starting July 2028

By Heather Phillips 05/08/2026 3 min read 19 views

Illinois will restrict certain cosmetic ingredients starting July 1, 2028, under the Chemicals in Cosmetic Products Act. The law prohibits the manufacture, sale, or offer for sale of cosmetic products containing 24 listed intentionally added chemicals or chemical forms.

Companies affected by this law should review their formulations, supplier information, and inventory practices for potential compliance issues. They should identify their cosmetic products sold or held for sale in Illinois and determine whether reformulation, ingredient substitution, or additional documentation may be necessary.

New Ingredient Restrictions for Cosmetics in Illinois

The law broadly defines a “cosmetic product” as a substance or mixture meant to be applied to clean, alter the appearance of, or protect the human body. The list of restricted chemicals includes dibutyl phthalate, diethylhexyl phthalate, formaldehyde, and 13 per- and polyfluoroalkyl substances (PFAS) and their salts.

The Environmental Protection Agency (EPA) has determined that some of these chemicals, such as dibutyl phthalate and diethylhexyl phthalate, present an unreasonable risk of injury to human health and the environment. The Consumer Product Safety Commission (CPSC) also prohibits children’s toys and child care articles containing more than 0.1 percent diethylhexyl phthalate.

Illinois Joins a Growing Patchwork of State and International Restrictions

Illinois joins other states, such as California and Maryland, that restrict specified chemicals in cosmetics. The EU Cosmetics Regulation also prohibits or restricts a substantially larger universe of substances, with prohibitions affecting more than 1,700 different chemicals and restrictions affecting the use of 380 others.

Companies should be aware that compliance with the Illinois law may not be the same as compliance with other state or international laws. They should compare the scope of covered products, ingredient definitions, knowledge standards, trace exceptions, supply chain practices, and operative dates under each law.

As the effective date of the Illinois law approaches, companies should use this time to identify covered products, obtain reliable ingredient information, evaluate reformulation and inventory needs, and allocate compliance responsibilities throughout their supply chains. Early planning will be particularly important due to the lack of an implementing agency, rulemaking process, or express enforcement framework.

It’s likely that companies will need to adapt to changing regulations and restrictions on cosmetic ingredients, not just in Illinois but also at the federal and international levels. The FDA continues to evaluate chemicals used in cosmetic products, and states are enacting broader consumer product statutes that create labeling, notification, or ingredient restriction provisions covering cosmetic products.

The absence of an express enforcement framework in the Illinois law creates uncertainty, but companies should not assume that the prohibition will be unenforceable. They should take a proactive approach to compliance, considering the potential risks and consequences of non-compliance, and be prepared to respond to any changes or updates to the law.

Implementation Questions and Future Compliance

The Illinois law leaves several implementation questions unresolved, including the definition of “knowingly” and the establishment of a penalty or remedy. Companies should be prepared to address these questions and ensure compliance with the law, even if it means seeking guidance from regulatory authorities or industry experts.

In the coming months, companies should focus on reviewing their formulations, supplier information, and inventory practices to ensure compliance with the Illinois law. They should also stay informed about any updates or changes to the law, as well as developments at the federal and international levels, to ensure they remain compliant and avoid any potential risks or consequences.