China: GB 7916 + No. 70 + No. 59 are the 2026 operating system. Archive, don’t discard. EU: 31 July 2026 placing cut for allergen labels. 2028 is not your friend if the unit is not yet placed. US: FDA PFAS report…
Leadership lineChina: GB 7916 + No. 70 + No. 59 are the 2026 operating system. Archive, don’t…
RA actionUnplaced EU old artwork should already have been blocked. China mercury date has passed — quarantine…
Buy the GB text. Diary its implementation clause. Keep STSC method and list files until a later announcement says otherwise. Children’s, eye and lip SKUs already had 2026 STSC move…
Treat No. 70 as a process redesign, not a holiday. Someone inside the company now owns the raw-material archive. Similar-formula evidence sharing can save a quarter — only if RA ca…
Inventory intentionally added PFAS now — that is the FDA report’s scope and most state laws’ scope. Do not quote the FDA report as a green light in a retailer portal. Illinois is a…
If the INCI is new in China, it is an NCI project under No. 59 from 15 July 2026. Budget it separately. EU: check annexes first; an SCCS opinion is not permission. US: no pre-marke…
This is a labeling project, not a perfume ban. If you place new EU stock after 31 July 2026, the expanded Annex III names must appear when thresholds are met. Stock already placed…
1. SCCS opinions ≠ annex law. 2. China method announcements (No. 51 and friends) are lab work. 3. Mercury STSC date 1 July 2026 was the China cliff at quarter-end. 4. FDA Voices is…
Tag every EU pallet as placed-before or not-yet-placed. After 31 July 2026, only the first group may keep old allergen lines. Fragrance houses need a written breakdown, not a Slack…
Column A (do now): facility listing, product listing, AE process, US contact. Column B (watch): GMP rule, fragrance-allergen rule, asbestos method (withdrawn Nov 2025). Column C (s…
Minute 0–5: official URL, document type, comment vs apply date. Minute 5–15: which of your INCIs are named. If none, stop. Minute 15–25: is this advice (SCCS) or a numbered announc…