What the FDA Has Planned for November, and Why Your Label Is About to Get Longer
On July 3, 2026, the Office of Information and Regulatory Affairs published the 2026 Regulatory Plan and Unified Agenda. It is not a document most founders read. It is simply a list of what federal agencies intend to work on and roughly when. Inside that list are two lines that will change what goes on the back of a cosmetic bottle.
Both are scheduled for November 2026. Both are proposals rather than final rules, which matters, and we will come back to that at the end.
The first proposal: formaldehyde in hair smoothing
The FDA intends to issue a Notice of Proposed Rulemaking that would prohibit formaldehyde and formaldehyde releasing chemicals, such as methylene glycol, in hair smoothing and hair straightening products that are used with heat.
If you do not make hair products, it is tempting to skip this one. I would not. The interesting part is the phrase "formaldehyde releasing". Those ingredients are not formaldehyde on the label. They are preservatives and other materials that release small amounts of it over time, which is exactly why a product can carry a formaldehyde free claim and still expose someone to formaldehyde when it is heated.
That gap between what a label says and what a product does is the thing regulators have been closing for several years now. Hair smoothing is where they started. It is not where they will stop.
The second proposal: fragrance allergens
The second proposal is the one that touches almost everyone making cosmetics in the United States. The FDA expects to publish a rule on the disclosure of fragrance allergens in cosmetic labeling, implementing the provisions introduced by the Modernization of Cosmetics Regulation Act. The rule would identify which substances have to be declared on the label as fragrance allergens.
Today a brand can write the single word fragrance, or parfum, and the conversation ends there. The blend behind that word is a trade secret of the fragrance house, and very often the brand owner does not know what is in it either.
Once the rule takes effect, that single word becomes a list. Specific allergens will have to be named. A consumer standing in a store will be able to read what used to be invisible, and so will a competitor, a journalist, and a retailer compliance team.
What quietly left the agenda
Two absences in this agenda are worth noticing, because they tell you where the pressure is and is not.
The proposed rule on testing methods for detecting and identifying asbestos in talc containing cosmetic products is no longer included. The FDA withdrew that rulemaking in late 2025. It was still present in the Spring 2025 agenda.
The Good Manufacturing Practice rule required under MoCRA does not appear in the current agenda either, which means its timeline remains uncertain. This is worth saying plainly, because GMP is one of the terms brands hear most often from manufacturers. A facility can be certified to a GMP standard today, and that is real. The federal MoCRA requirement is a separate thing, and it has not been issued yet. If your manufacturer tells you they are MoCRA compliant on GMP, ask them which of the two they mean.
Four questions worth asking before November
If you own a brand, none of this requires panic. It requires four conversations, and all of them are easier now than in November.
- Ask your fragrance supplier for the allergen declaration for your specific blend. Most reputable houses can produce one. If yours cannot, that is information.
- Ask your manufacturer which preservative system your formula uses, and whether any component of it releases formaldehyde. The answer should be immediate, not researched.
- Ask whether your current label artwork has physical room for a longer ingredient list. Redesigning a carton under deadline is expensive. Redesigning it calmly is not.
- Ask what your timeline is for the next production run. If you are printing labels in the next few months, it is worth knowing what is coming before the plates are made.
The honest caveat
These are proposals, not finished rules. A Notice of Proposed Rulemaking opens a comment period, the agency reads what the industry sends, and the final rule can arrive later and look different. Regulatory timelines move. This one has moved before.
So the correct reading is not that something becomes illegal in November. The correct reading is that the direction is set, it has been set for a while, and the brands that find out what is inside their own products early will simply have less work to do than the ones that wait.
At Vaulabs we build formulas with the disclosure in mind from the start, because a product that can be explained is a product that can be sold anywhere.
Source: 2026 Regulatory Plan and Unified Agenda, Office of Information and Regulatory Affairs, published July 3, 2026. Reported by ChemLinked, July 9, 2026.
Not sure what is inside your own formula?
We build clean beauty formulas for brands that have to answer that question in front of a retailer. Send us your current INCI and we will tell you plainly what would change.