Personal care companies scrambling to meet the post-consumer recycled (PCR) content requirements of Washington state’s SB 5022 in just over a month could face formula stability issues and material shortages, warns Angela Diesch, attorney at Amin Wasserman Gurnani, LLP.
WA State Recyclability Law One-Month Countdown Begins; Cosmetic Packaging Procrastinators Warned
Personal care packaging producers should be prepared for Washington state’s 1 January deadline for ensuring personal care product containers are made up of at least 15% post-consumer recycled material, notes Angela Diesch, attorney at Amin Wasserman Gurnani, LLP, during a webinar hosted by Global Victoria, the trade facilitation agency for the state of Victoria in Australia.

More from Compliance
Single-use packaging producers obligated under Oregon’s Extended Producer Responsibility law who still haven’t registered with program facilitators will struggle at this point to meet the fast-approaching material-reporting deadline, but should nonetheless jump into the process, says EPR consultant Michael Washburn.
Many small US and independent beauty brands are still unfamiliar with the Modernization of Cosmetics Regulation Act, as are owners of beauty brands based outside the US; the lack of education about the regulation is making many stakeholders at risk for non-compliance.
FDA publishes an updated registration guidance in the Federal Register 12 December to answer outstanding questions by stakeholders, including whether a single FEI number can be used for multiple related facilities.
The Washington State Department of Ecology will take interim policy action by 1 January, 2025 that will provide manufacturers alternative paths to compliance with the 1ppm lead limit under the state’s Toxic Free Cosmetics Act, the agency announces. It also anticipates opening a rulemaking related to lead impurities in cosmetics in 2025.
More from HBW Insight
Jump in cough & cold sales at the end of the year helps Recordati post higher OTC revenues for 2024.
Changes established in West Virginia and proposed in numerous other states gained momentum after Trump was elected to his second term as president and nominated Kennedy to head HHS.
Personal care companies selling in California that suspect they are subject to its listing of a common stabilizer and packaging material should collect Certificates of Analysis for all raw materials, pursue third-party formula testing and retain counsel.