Illinois Enacts 2028 Ban on PFAS and Other Chemicals in Cosmetics
Springfield, Illinois, 10 July 2026 — Illinois has enacted a law prohibiting cosmetics containing certain intentionally added PFAS, phthalates, formaldehyde-related substances, mercury, parabens, and hair-dye chemicals beginning 1 July 2028.
Under the Chemicals in Cosmetic Products Act, a person may not knowingly manufacture, sell, deliver, hold, or offer for sale in Illinois a cosmetic product containing any of the listed ingredients.
The law applies to makeup, hair and nail products, soaps, lotions, tanning products, perfumes, and other products intended to clean, protect, or alter the appearance of the human body.
Chemicals covered by the ban
The law prohibits intentionally added
Dibutyl phthalate and diethylhexyl phthalate;
Formaldehyde, paraformaldehyde, methylene glycol and quaternium-15;
Mercury;
Isobutylparaben and isopropylparaben;
m-Phenylenediamine and o-phenylenediamine, including their salts; and
Thirteen specifically identified PFAS substances and salts.
The chemicals serve different functions in cosmetic formulations. Phthalates may be used as solvents or plasticizers, while formaldehyde-related substances may function as preservatives or release formaldehyde under certain conditions.
Quaternium-15 is a formaldehyde-releasing preservative, while methylene glycol is the hydrated form of formaldehyde commonly found in water-based solutions.
The law also targets mercury, which has been identified in some skin-lightening products, and two parabens used as preservatives.
The listed m- and o-phenylenediamines are aromatic amines associated with dye chemistry. They are distinct from p-phenylenediamine, a separate substance commonly used in permanent hair dyes.
PFAS deadlines for cosmetics in Illinois
The new law builds on an existing Illinois law enacted in 2025 that will prohibit all intentionally added PFAS in cosmetics beginning 1 January 2032.
Before that broader prohibition takes effect, the Chemicals in Cosmetic Products Act will ban 13 specifically named PFAS substances and salts beginning 1 July 2028.
The listed substances are associated with PFOS, PFOA, PFDA, and PFNA and include certain ammonium, potassium, sodium, lithium, and diethanolamine salts.
Trace quantities may be exempt
The law provides a limited exemption for technically unavoidable trace quantities.
A product is not in violation if it was manufactured through a process intended to comply with the law and the restricted substance is present only as an unavoidable trace resulting from the following:
An impurity in a natural or synthetic ingredient;
Manufacturing;
Storage; or
Packaging.
The exemption does not establish a general allowable concentration. Companies relying on it should maintain records showing that the substance was not intentionally added and could not technically be avoided.
Illinois joins broader U.S. and EU action
While lawmakers in Illinois intended for the Chemicals in Cosmetic Products Act to be consistent with ingredient prohibitions adopted by the European Union under its Cosmetics Regulation, these requirements also mirror a growing group of states restricting PFAS and other chemicals in cosmetics.
California and Maryland began prohibiting several similar substances in 2025, while California also restricts intentionally added PFAS as a broader class.
Washington began restricting intentionally added PFAS, formaldehyde, methylene glycol, ortho-phthalates, and certain phenylenediamines in cosmetics in 2025.
Colorado and Minnesota also began prohibiting intentionally added PFAS in covered cosmetics in 2025, followed by restrictions in Vermont and Maine beginning in 2026.
Additional PFAS restrictions affecting cosmetics are scheduled in Rhode Island, New Mexico, and New Jersey. New York lawmakers have also considered the Beauty Justice Act, which would establish a process for evaluating and restricting potentially harmful cosmetic ingredients.
Because state requirements differ, compliance with the Illinois 2028 list may not be sufficient elsewhere. Some states regulate named chemicals, while others prohibit intentionally added PFAS as an entire class.
Implications for industries
Manufacturers, importers, distributors, and retailers should review products intended for the Illinois market well before July 2028 to remove the specifically listed substances by July 2028 and eliminate all intentionally added PFAS by January 2032. Businesses reformulating products may benefit from preparing for the broader 2032 ban from the outset rather than making separate formulation changes for each deadline. Companies whose products are already compliant in California, Colorado, Maine, and Vermont may experience little to no regulatory burden.
However, all companies should compare formulations and supplier data against the listed chemical names and CAS numbers, identify PFAS salts and formaldehyde-releasing ingredients, and document any technically unavoidable trace quantities. Because the law also covers selling, delivering, holding, and offering products for sale, compliance responsibilities extend throughout the cosmetic supply chain.
