Prohibited Cosmetic Ingredients: Federal Bans, State Laws and Amazon's List

An ingredient can be legal under federal law, banned in California since 2025, banned in Washington on the same day, and due to be banned in Oregon in 2027, and Amazon ships to all of them. A cosmetic that contains a prohibited ingredient is adulterated under FD&C Act section 601 and cannot be sold; a state ban applies to sale into that state from its effective date whatever the federal status. For a seller whose inventory sits in fulfilment centres across the country, the strictest applicable rule is the one that matters.

This guide lays out the federal prohibitions, Amazon's own list for cosmetics, the state bans with their dates, the hydroquinone question, and the one way an honest "free-of" claim gets mistaken for an ingredient disclosure.

Federal prohibitions: 21 CFR 700 subpart B

FDA's prohibited and restricted cosmetic ingredients sit in 21 CFR 700 subpart B, with two companions elsewhere:

• Bithionol (700.11): prohibited.
• Mercury compounds (700.13): prohibited, except as a preservative in eye-area products at up to 65 ppm where no effective alternative exists. California and Washington ban mercury outright from 2025-01-01, as do Vermont and Oregon, so the federal exception is academic for a national seller.
• Vinyl chloride (700.14): prohibited as an aerosol ingredient.
• Halogenated salicylanilides (700.15): tribromsalan, tetrachlorosalicylanilide, dibromsalan and metabromsalan, prohibited.
• Zirconium complexes (700.16): prohibited in aerosol cosmetics.
• Chloroform (700.18) and methylene chloride (700.19): prohibited.
• Chlorofluorocarbon propellants (700.23): prohibited, and a named item on Amazon's prohibited list too.
• Hexachlorophene (21 CFR 250.250): limited to 0.1% as a preservative where no alternative is available.
• Plastic microbeads: banned in rinse-off cosmetics since 2018-07-01 under the Microbead-Free Waters Act.

Few modern formulas contain any of these. The risk for an Amazon seller is a legacy import, a grey-market product, or a listing whose copy mentions one of them in a way an automated scan reads as an ingredient.

Amazon's prohibited cosmetics list

Amazon's Restricted Products page for cosmetics and skin and hair care adds a layer that is partly federal law restated and partly Amazon's own. Not permitted:

• Skin creams or soaps containing mercury.
• Tanning pills containing canthaxanthin.
• Products with CFC propellants.
• Permanent eyelash or eyebrow dyes.
• Kohl, kajal, al-kahal or surma.
• Listings making disease claims.
• Adulterated or misbranded products, including those containing bithionol, chloroform, halogenated salicylanilides, methylene chloride, vinyl chloride or zirconium in aerosols, and Brazilian Blowout and similar formaldehyde smoothing products.
• Expired, opened or tester units.
• Products with altered or removed lot codes or manufacturer information.
• Products lacking FDA-required labeling.
• Prescription-only products, for example minoxidil above 5%.

Three of those are not ingredient bans at all. "Listings making disease claims" is the cosmetic-versus-drug line. "Products lacking FDA-required labeling" covers the 21 CFR 740 warnings, the ingredient declaration and the MoCRA contact line. The lot-code item is why relabelled or decanted stock is a prohibited-product problem and not merely a brand-registry one.

Hydroquinone: Amazon's 2% and FDA's zero

Amazon prohibits skin lighteners with more than 2% hydroquinone. FDA's position is stricter. The 2020 CARES Act removed hydroquinone from the OTC monograph, and FDA now treats any OTC hydroquinone product as an unapproved new drug. A listing that names hydroquinone at 2% is inside Amazon's line and outside FDA's. Treat any hydroquinone mention, other than a "hydroquinone-free" claim, as a review item rather than a pass.

State bans: California and Washington first

The state laws are where most of the live risk sits, because they reach ingredients that are common in older formulas.

California, Toxic-Free Cosmetics Act (AB 2762, Cal. Health & Safety Code 108980). From 2025-01-01 a cosmetic containing any of 24 intentionally added ingredients may not be manufactured, sold or distributed in California: dibutyl phthalate and diethylhexyl phthalate, formaldehyde, paraformaldehyde, methylene glycol, quaternium-15, mercury, isobutylparaben and isopropylparaben, m- and o-phenylenediamine and their salts, and 13 named PFAS. AB 496 adds 26 further ingredients from 2027-01-01, among them lilial (butylphenyl methylpropional) and cyclotetrasiloxane.

Washington, Toxic-Free Cosmetics Act (RCW 70A.560). From 2025-01-01 cosmetics sold in Washington may not contain intentionally added ortho-phthalates, PFAS, formaldehyde, methylene glycol, mercury, triclosan, m- or o-phenylenediamine, or lead at 1 ppm or more. Formaldehyde-releasing agents identified by Ecology rule are restricted from 2027-01-01.

Note the differences. Washington bans the whole ortho-phthalate class and triclosan, which California's 2025 list does not; California names quaternium-15 and the two parabens, which Washington's does not. A formula has to clear both.

The 2026 and 2027 wave

• Vermont (Act 131) takes effect in 2026 with a further list from 2027-07-01, reaching formaldehyde, methylene glycol, quaternium-15, phthalates, mercury, triclosan, lead, asbestos and 1,4-dioxane (intentional use, or 10 ppm or more), with cyclotetrasiloxane, toluene and styrene joining in 2027.
• Oregon (SB 546) takes effect 2027-01-01, with ortho-phthalates, formaldehyde releasers, triclosan, PFAS and lead at 10 ppm or more.
• PFAS bans in Minnesota and Colorado from 2025-01-01, Vermont and Maine from 2026-01-01, Oregon from 2027-01-01.
• New York (ECL 37-0117) limits 1,4-dioxane to 10 ppm in cosmetics since 2022-12-31 and 1 ppm in personal care products since 2023-12-31. Unlike the others this is a concentration limit rather than a ban on intentional use, so the evidence is a test result rather than an ingredient list.

The formaldehyde releasers deserve a specific audit. DMDM hydantoin, imidazolidinyl urea, diazolidinyl urea, bronopol (2-bromo-2-nitropropane-1,3-diol) and sodium hydroxymethylglycinate are ordinary preservatives in thousands of hair-care formulas, legal federally, and restricted in Washington by rule and in Oregon from 2027. A reformulation takes longer than a label change, so the clock on these started some time ago.

The free-of trap

Automated ingredient scans read listing text as well as the ingredients attribute, and "formaldehyde" in a bullet looks the same as "formaldehyde" in an INCI list unless the scanner is built to tell them apart. A well-built check treats "free of", "free from", "no", "without", "zero", "non-" and the "-free" suffix as negation, so "formaldehyde-free" and "no parabens" pass. Loose phrasings do not always: "we removed formaldehyde from our formula in 2023" is a true sentence that names a banned ingredient in a context a scanner cannot resolve.

Write free-of claims in the hyphenated form, "phthalate-free", "triclosan-free", and keep the reformulation story out of the bullets. Then confirm the claim against the actual list, since a free-of claim contradicted by the INCI declaration is its own finding.

California reporting duties and the Prop 65 attribute

Two California programmes report rather than ban, and both are triggered by the ingredient list.

Under the Cosmetic Fragrance and Flavor Ingredient Right to Know Act (SB 312, Health & Safety Code 111792.6), since 2022-01-01 a manufacturer of a cosmetic sold in California reports to CDPH each fragrance or flavor ingredient that appears on one of 23 designated hazard lists, and each EU Annex III fragrance allergen present at or above 0.01% in rinse-off or 0.001% in leave-on products. Ingredients newly added to a list are reported within six months. If "Parfum" or "Fragrance" is on your INCI list, this applies to you.

Under the California Safe Cosmetics Act (Health & Safety Code 111791 to 111793), a manufacturer with $1,000,000 or more in annual aggregate cosmetic sales reports every cosmetic sold in California containing an ingredient an authoritative body has identified as a carcinogen or reproductive toxicant. The CDPH Safe Cosmetics Program runs both.

Finally, where a Proposition 65 warning applies, Amazon expects it to be provided through the listing's Prop 65 attribute so that it displays before purchase. Titanium dioxide in loose powders and coal-tar dyes are the usual cosmetic triggers.

What to do with a flagged ingredient

1. Confirm the ingredient is actually in the formula. Pull the manufacturer's INCI list, not the marketing sheet.
2. If it is a free-of statement misread as an ingredient, rewrite the claim in hyphenated form and move on.
3. If the ingredient is present and banned federally, the product cannot be sold; stop and pull inventory.
4. If it is banned in some states, reformulate before the effective date and restrict fulfilment to the unaffected states until the new formula ships.
5. Update the ingredients attribute, the label image and every bullet in the same pass, so the listing does not contradict itself during the transition.
6. If Amazon has already removed the listing, the appeal is a plan of action that names the ingredient, the rule and the corrected formula or copy; the structure in our plan of action guide carries across categories.

Keeping a catalogue's ingredient lists checked against a ban list that changes state by state and year by year is a job for software. Verid8 reads the INCI declaration from the attributes and the label image, checks it against the federal, Amazon and state lists with their effective dates, and separates a free-of claim from an ingredient disclosure before it reports anything. The Beauty & Personal Care page lists the full set.

The federal list is short and old. The state lists are long and getting longer, and they are the ones a national Amazon seller is actually measured against.