Illinois has enacted a cosmetic ingredient restriction that will reshape formulation and sourcing decisions for any brand selling into the state. On 10 July 2026, Governor JB Pritzker signed the Chemicals in Cosmetic Products Act (HB 3409) as Public Act 104-0545. Beginning 1 July 2028, the Act prohibits manufacturing, selling, delivering, holding, or offering for sale any cosmetic product containing any of 24 intentionally added listed ingredients.

For compliance, quality, and supply-chain leaders, the practical question is not whether the deadline is distant. It is whether formulation records, supplier declarations, and bill-of-materials data are accurate enough to prove the absence of 24 named substances across a full portfolio. That is a documentation and traceability problem, and it takes most of the two-year transition window to solve properly.

What HB 3409 Actually Restricts

The Act creates a prohibition, not a reporting scheme. It targets ingredients that are "intentionally added" to a cosmetic product, defined broadly as a substance or mixture applied to the human body to clean it, change its appearance, or protect it. The definition incorporates the federal meaning of "cosmetic" under 21 U.S.C. 321, so the covered universe includes makeup, hair and nail products, soaps and lotions, tanning products, and fragrances.

The 24 prohibited ingredients fall into two groups. This distinction matters when scoping formulations, because a PFAS-only review will miss more than a third of the list. Teams already managing PFAS compliance obligations should treat this as a broader chemical restriction, and teams accustomed to REACH and SVHC screening will recognize the substance-list logic.

The complete enumerated list with CAS numbers is set out in Section 15(a) of the Act. The PFAS provision restricts the specific PFAS expressly identified in the statute. It is not a blanket ban on all per- and polyfluoroalkyl substances, which is a meaningful distinction for substitution planning.

Who Is Affected

The prohibition reaches every point in the cosmetics supply chain that touches the Illinois market. Because the ban covers holding and offering for sale, not only manufacturing, distributors and retailers carry independent exposure even when they did not formulate the product. Companies mapping obligations across the consumer goods sector should scope each of the roles below.

🏭 Manufacturers and brand owners formulating or contracting cosmetics sold into Illinois

🔗 Importers and distributors placing covered products into the Illinois market

📄 Retailers and e-commerce sellers holding or offering covered cosmetics for sale

📊 Raw-material and ingredient suppliers who must substantiate impurity profiles and intentional-addition status

The regulatory pattern is not isolated. California, Maryland, Washington, and Oregon maintain overlapping cosmetic ingredient restrictions, and the same substances recur across state statutes. Organizations tracking the wider shift can review Certivo's analysis of cosmetics industry regulatory shifts and the broader state PFAS regulation landscape to avoid managing each state as a one-off.

Illinois HB 3409 banned cosmetic ingredients PFAS and chemical categories

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The Trace-Quantity Exemption Is Narrow and Conditional

HB 3409 contains one substantive exemption, and it is limited. A person is not in violation if the cosmetic product meets both of the following conditions: it was manufactured through a process intended to comply with the Act, and it contains only a technically unavoidable trace quantity of a listed ingredient resulting from an ingredient impurity or the manufacturing, storage, or packaging process.

The Act does not define a numerical threshold for "trace quantity." That places the substantiation burden on the company. To rely on the exemption, a manufacturer must be able to show both the origin of the trace amount and the design of a compliant process. Separately, the Act excludes an "incidental ingredient" as described in 21 CFR 701.3(l) from its definition of "ingredient," which is a distinct carve-out from the trace-quantity provision.

For most portfolios, the exemption is a documentation exercise, not a shortcut. It rewards teams that can produce supplier impurity data and process records on demand, and it penalizes those relying on informal or incomplete declarations.

Reporting, Documentation, and Data Challenges

There is no submission or registry under HB 3409. The obligation is to not place a non-compliant product on the market, and to be able to demonstrate that position if challenged. In practice, that shifts the work into supplier data and BOM management.

The recurring difficulties are familiar to any team that has run a substance-restriction program at scale:

⚠️ Incomplete supplier declarations that confirm a formulation but do not address impurity-level presence of listed substances

📊 Fragmented formulation records spread across contract manufacturers, private-label partners, and legacy documents

🔗 Multi-tier visibility gaps, where the intentional-addition status of a substance sits two or three tiers upstream

Resolving these depends on reliable BOM substance and threshold management and on structured supplier documentation collection rather than email chains. AI document parsing and certificate validation can accelerate intake by reading supplier declarations and flagging where a listed CAS number appears or where required impurity substantiation is missing.

Compliance Risk and Enforcement Exposure

The exposure is market-access risk. A product containing a listed intentionally added ingredient may not be manufactured, sold, delivered, held, or offered for sale in Illinois once the prohibition takes effect. Because the restriction attaches to commercial activity across the chain, a single non-compliant formulation can create liability for the manufacturer, the distributor holding stock, and the retailer offering it.

Three audit contexts are relevant. Customer audits from major retailers increasingly require documented proof of ingredient compliance before onboarding. Internal audits need point-in-time evidence that a formulation was compliant when placed on the market. And state enforcement, should it arise, will turn on whether a company can produce contemporaneous records. Maintaining audit-ready documentation across frameworks is what converts a reformulation effort into defensible evidence.

Timeline and How This Fits the Broader Illinois Picture

HB 3409 is one of two distinct Illinois measures that reach cosmetics, and conflating them is a common error. The table below separates them.

Both are confirmed against the Illinois General Assembly record. The PFAS framework obligations therefore arrive in two waves for Illinois cosmetics: the named-substance prohibition in 2028, followed by the broader intentionally added PFAS restriction in 2032. Planning to the earlier date, and to the full 24-ingredient list, is the conservative position.

Strategic Preparation Checklist

The two-year window is adequate only if reformulation and supplier substantiation start early. Priorities for a global manufacturer:

1. Scope the portfolio. Flag every cosmetic SKU sold, distributed, or held in Illinois against all 24 listed ingredients, not PFAS alone.

2. Map substances to BOMs. Link each listed CAS number to specific formulations and components so exposure is visible at the product level.

3. Engage suppliers now. Request updated declarations covering both intentional addition and impurity-level presence, with substantiation for any trace-quantity reliance.

4. Plan substitutions. Identify reformulation candidates and validate replacements against other state cosmetic bans to avoid solving Illinois while creating a California or Maryland problem.

5. Preserve evidence. Retain time-stamped declarations and process records that establish compliance at the point of market placement.

How Certivo and CORA Support Illinois Cosmetics Compliance

Certivo functions as the system of record for product compliance, with CORA providing the embedded regulatory intelligence. For HB 3409, that translates into three concrete capabilities. Chemical and hazmat compliance workflows map the 24 listed substances to formulations and BOMs, so a team can see which products carry exposure. Automated supplier and contractor management collects and validates declarations at scale, and CORA-powered regulatory intelligence tracks how Illinois and adjacent states change their restricted-substance lists over time.

The objective is not to eliminate compliance risk. It is to reduce surprises, shorten evidence-retrieval time, and move from reactive checks toward continuous, audit-ready readiness. For teams still working from spreadsheets, the shift to a centralized compliance data backbone is what makes a 24-substance, multi-state obligation manageable rather than a recurring fire drill.

To assess your Illinois cosmetics exposure across products and suppliers before the 2028 deadline, book a compliance risk assessment.