Regulatory Updates in France, Canada and Thailand

Canada - Changes to the Cosmetic Ingredient Hotlist

On 28th February 2025, Health Canada published changes to its Cosmetic Ingredient Hotlist, adding two items - Retinal and Thioglycolic acid esters - and amending four.

You may read the details of the amendments here.

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Canada - PFAS Risk Management Plan

Health Canada and Environment and Climate Change Canada jointly published a Risk Management Approach document for PFAS (Per- and polyfluoroalkyl substances), excluding fluoropolymers, in March 2025. The Government of Canada is proposing new risk management actions for PFAS through a phased prohibition (across three phases) under CEPA (Canadian Environmental Protection Act). Paragraphs 64(a) and (c) of CEPA define the criteria under which substances may be considered as 'toxic', and the Risk Management Approach document concludes PFAS (excluding fluoropolymers) meet this criteria.

Phase 1: "Prohibition of the use of PFAS (excluding fluoropolymers) not currently regulated in firefighting foams, due to a high potential for environmental and human exposure."

Consultation planned for Summer/Fall 2025; Proposed regulation planned for Spring 2027.

Phase 2: "Prohibition of the uses of PFAS (excluding fluoropolymers) not needed for the protection of health, safety or the environment, which includes consumer applications. Prioritization of uses for prohibition is based on, and will take into account, costs and benefits, availability of suitable alternatives and other socioeconomic considerations." (Includes cosmetic applications).

Consultation to follow the publication of proposed Phase 1 Regulations: 2027.

Phase 3: "Prohibition of the uses of PFAS (excluding fluoropolymers) for which currently there may not be feasible alternatives and requiring further evaluation of the role of PFAS for which currently there may not be feasible alternatives and taking into consideration socio-economic factors."

Consultation to follow Phase 2 risk management.

You may view the Risk Management Approach here.

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Canada - Cosmetic Notification Form Amendment

On 5th March 2025, Health Canada updated its cosmetic notification form to include an entry for a Canadian-based representative. A Canadian-based representative is now required to sell cosmetic on the Canadian market. This change was announced in April 2024, [here ](http://Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients: SOR/2024-63)(see the definition for 'manufacturer').

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France Passes PFAS Bill for Cosmetics

On 27th February 2025, France promulgated Law No. 2025-188 to protect the population from the risks associated with PFAS (per- and polyfluoroalkyl substances). From 1st January 2026, the manufacture, import and placing on the market of cosmetic (among other consumer applications) products containing PFAS shall be prohibited. Limits for residual levels of PFAS are still to be determined.

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Thailand - Cosmetic Ingredient List Updates

On 28th February 2025, the Thai government published nine draft laws to comply with the ASEAN Cosmetics Act. These include changes to existing ingredient entries, the removal of two permitted preservatives and additional restricted and prohibited ingredients.

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All drafts can be found here.