Comparative Studies of Cosmetics Regulations Between the USA, Canada, Australia, and the EU

Abstract

Abstract

Cosmetic products occupy a central role in personal and professional care. Over recent decades, the market has grown substantially, necessitating robust regulations to maintain product integrity and promote harmonization. This review presents a comparative analysis of the regulatory frameworks governing cosmetics across the United States of America (USA), the European Union (EU), Canada, and Australia. It focuses primarily on safety requirements, ingredient restrictions, labelling requirements, and post-market surveillance. This review was conducted using official regulatory guidelines, peer-reviewed literature, and regulatory documents to analyse variations across these regions systematically. The findings indicate that the EU follows stringent regulations with strict premarket safety assessments under Regulation (EC) No. 1223/2009, whereas the USA, under the Modernization of Cosmetics Regulation Act (MoCRA), adopts a more flexible, post-market-oriented approach and also addresses facility registration, product listing, and adverse event reporting within defined timelines. Canada focuses on ingredient safety through the Cosmetic Ingredient Hotlist and mandates product notification and bilingual labelling, while Australia regulates cosmetics through dual frameworks—the Australian Industrial Chemicals Introduction Scheme (AICIS) and the Therapeutic Goods Administration (TGA)—focusing particularly on premarket approval, ingredient control, and enforcement mechanisms, highlighting gaps across global manufacturers and the need for greater harmonization to ensure consumer safety and maintain product quality across international trade.