New Zealand Imposes Requirements for Non-hazardous Cosmetics

By Lily Hou, PhD, CHMM, Regulatory Affairs Lead, Supply Chain team, UL Solutions

Starting from December 31, 2025, non-hazardous cosmetic products that contain a hazardous ingredient will become legally required to comply with the New Zealand Cosmetic Products Group Standard. The new requirement is a part of the amended Cosmetic Products Group Standard 2020, released by the New Zealand Environmental Protection Agency (EPA) on January 30, 2024.

Background

In New Zealand, the primary rules that cosmetics must comply with are the Cosmetic Products Group Standard 2020. The group standard regulates a cosmetic product in mainly two areas: one is controlling the safety of its ingredients by specifying prohibited ingredients, restricted ingredients, and allowed colorants, preservatives and UV filters; the other is setting out conditions for compliance with EPA Notices, including labelling, SDS and packaging, etc.

To meet the requirements of the group standard, manufacturers and importers of cosmetics need to make sure their products only contain the ingredients that are permitted to be used by the group standard, and strictly follow the rules on the SDS, labeling, packaging, and storage of the products.

The amendment introduced the following changes to the Group Standards:

• Expanded the scope of the Group Standard to include non-hazardous cosmetic products that contain a hazardous substance.
• Updated Schedule 4 to Schedule 8 to align with the EU Annexes.
• Removed the requirement for the 24 hour emergency phone number from the label.
• Phase out PFAS by adding them to the list of prohibited ingredients (Schedule 4, Table 2 of the group standard).
• Added United Kingdom to the alternative labelling compliance list.
• Other changes including the requirements for fragrances and nanomaterials.

Regulatory Impact on Non-hazardous Cosmetics

Before the amendment, the group standard only applied to a cosmetic product that classifies as hazardous according to the EPA Hazardous Substances (Hazard Classification) Notice 2020. The amendment extended the scope of the group standard to include any cosmetic product that does not classify as hazardous but contains a component that classifies as hazardous according to the EPA Classification Notice.

Considering the finished cosmetics are not hazardous, the EPA won’t regulate them the same way as hazardous cosmetics. The following table shows whether some obligations may or may not apply to hazardous cosmetics and non-hazardous cosmetics with hazardous ingredients.

While manufacturers and importers are not required to make SDS for non-hazardous products, it is considered a good practice to provide SDS for business continuity. For non-hazardous products containing either hazardous ingredient in low concentration or non-hazardous ingredients only, Section 2 of the SDS may include the same hazard classification “non-hazardous,” however, different wording may be needed for Section 15 of the SDS. The Hazardous Substances Reassessments team from the NZ EPA provide some good suggestions on how to choose different languages in Section 15 of the SDS:

“In section 15, for non-hazardous cosmetics containing a hazardous ingredient, use words like ‘non-hazardous but assigned to the Cosmetic Product Group Standards’; for products not containing a hazardous ingredient, use words like “non-hazardous, complies with the Cosmetic Product Group Standards.”

Transition Period

For import and manufacture, the amendment takes effect on Dec 31, 2025 except for cosmetics containing PFAS, which has a longer transition period till December 31, 2026. For supply, the amendment becomes mandatory on Dec 31, 2026, but cosmetics containing PFAS may continue to be supplied till December 31, 2027.

Recommended Actions for Non-hazardous Cosmetic Products

Re-evaluate non-hazardous cosmetics in your inventory, and ensure the following obligations are met for the products that contain a hazardous ingredient:

• Comply with the rules for inclusion and labeling of the ingredients (Schedules 4 to 8 of the group standards).
• Label in accordance with Schedule 1 of the group standard and provide contact details of the NZ importer or manufacturer.
• Keep a record of group standard assignment, which must be available for inspection if requested by a HSNO enforcement officer.

References

Cosmetic Products Group Standard 2020
Decision-making Committee’s decision
Record of Group Standard assignment
EPA updates to the Cosmetics Products Group Standard
Transcript of the Cosmetic Products Group Standard hearing
Update Report for Proposal to amend the Cosmetic Products Group Standard