
If you operate a salon, retail store, or distribute cosmetics in Washington state, the clock is ticking.
The sell-through period under Washington’s Toxic-Free Cosmetics Act (TFCA) officially ends December 31, 2025. Starting January 1, 2026, non-compliant cosmetic products can no longer be sold, used, or donated in Washington — regardless of when they were originally purchased.
This deadline marks a major transition point for the beauty supply chain, and businesses with older inventory should be acting now.
Washington’s TFCA, which took effect January 1, 2025, restricts the manufacture, sale, distribution, and use of cosmetic products that contain certain toxic chemicals linked to human health and environmental harm.
The law applies broadly across the supply chain — including manufacturers, distributors, retailers, salons, and e-commerce sellers — and covers products used to cleanse, beautify, or alter appearance, such as:
To ease the transition, Washington allowed businesses to continue selling or using pre-2025 inventory during a one-year sell-through period.
That grace period ends December 31, 2025.
Beginning in 2026, salons, retailers, and distributors may not:
Any remaining inventory that contains restricted substances must be removed from shelves and service areas.
As Washington Department of Ecology’s Shari Franjevic puts it:
“Cosmetics that retailers and salons in Washington received in 2025 should already meet the new restrictions in the law, but older stock might not. The close of the sell-through period means fewer toxic chemicals in homes, stores and salons.”
The TFCA restricts several chemical classes and substances when they are intentionally added — and, in some cases, even when present as impurities.
Key restricted chemicals include:
With the deadline approaching, Washington Ecology recommends businesses take the following steps:
If a product is applied to the human body for cosmetic purposes, it’s likely covered. This includes back-bar salon products, professional-use-only items, and retail SKUs.
To assess compliance, businesses can:
Use a compliance checker
For a faster first pass, Smarter Sorting has built a free Washington TFCA Cosmetic Checker that allows salons and retailers to quickly assess whether a cosmetic product may contain TFCA-restricted chemicals.
The tool is designed to help businesses triage older inventory and identify products that may require closer review or supplier follow-up.
Try the Washington TFCA Cosmetic Checker: https://wa-cosmetic-checker.replit.app
Products that don’t meet TFCA requirements must be:
Note: Retailers should evaluate whether products prohibited in Washington should continue to be sold in other states. Many retailers prioritize customer health and safety and choose not to offer products anywhere if they are restricted in one state.
Some cosmetic products may qualify as dangerous waste under Washington law and may require specialized disposal methods rather than standard trash handling.
Washington Ecology provides detailed guidance on disposal pathways for cosmetic products.
One of the most important takeaways from TFCA enforcement is that compliance doesn’t stop at the shelf.
Restricted chemicals can be:
Because of this, responsibility spans the entire supply chain:
As Franjevic notes:
“Retailers and cosmetologists need to sell and use compliant products. To do that, distributors must provide compliant products. Manufacturers and brands must know what’s in their products and formulate compliant products. Responsibility really goes all the way up the supply chain.”
TFCA isn’t just a paperwork exercise.
Many restricted cosmetic chemicals are linked to:
These substances can enter waterways when products are washed down drains or disposed of improperly, affecting water quality and wildlife health.
The goal is simple: people shouldn’t need a chemistry degree to buy safer products.
Deadlines like this highlight a growing reality for retailers and salons: product data accuracy and chemical transparency are now core compliance requirements, not nice-to-haves.
Knowing what’s in your products — and where regulatory risk hides — is becoming just as important as pricing, inventory, and merchandising.
Looking ahead, Smarter Sorting customers will have the ability in 2026 to subscribe to full-catalog TFCA audits, enabling ongoing monitoring of cosmetic product portfolios for Washington compliance as regulations evolve.
Not a Smarter Sorting customer? Get in touch to learn how automated compliance audits can help reduce regulatory risk across your entire catalog.