Cosmetic Supply Chain Transparency Act of 2025

The Cosmetic Supply Chain Transparency Act of 2025 would overhaul cosmetic regulation by creating a new Supply Chain Transparency subchapter within the Federal Food, Drug, and Cosmetic Act. It requires brand owners to obtain detailed information from suppliers about cosmetics and their ingredients, including functions, hazards, properties, safety data, manufacturing processes, and ingredient lists, with a 90-day response deadline. The bill also establishes a process for the FDA to create and maintain a list of nonfunctional constituents (NFCs)—chemicals present in cosmetics that do not contribute to product function but may pose health or environmental risks—drawn from multiple international and U.S. lists. Once an NFC is added to the list, suppliers must test for it within a year and provide the brand owner with a certificate of analysis detailing levels, tests used, detection limits, and heavy metal results. The act sets up an advisory committee, a petition process for adding constituents or lists, annual updates, and civil penalties for noncompliance. States are allowed to maintain stricter rules unless the act explicitly preempts them, and the measure includes data collection provisions during adulteration or recall cases.