Judgment
Judgment on what matters — linked to regulatory news.
10 insights
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…
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 Do not quote the FDA report as a green light in a retailer portal.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 Column B (watch): GMP rule, fragrance-allergen rule, asbestos method (withdrawn Nov 2025).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…