New Zealand's Cosmetic Products Group Standard Explained
How the EPA NZ Cosmetic Products Group Standard's schedules track EU cosmetics rules, where they currently differ, and what that means for dual-market brands.
New Zealand does not have its own equivalent of the EU Cosmetics Regulation. Instead, cosmetics are regulated as a category of hazardous substance under the Hazardous Substances and New Organisms Act 1996 (the HSNO Act), through a single instrument called the Cosmetic Products Group Standard. It is issued and administered by the Environmental Protection Authority (EPA), and it is the reason a formulator selling into New Zealand needs to check a second rulebook even after clearing the EU annexes.
What the Group Standard is and who administers it
The current instrument is the Cosmetic Products Group Standard 2020 (HSR002552), issued under the HSNO Act 1996. It was substantially amended by the Cosmetic Products Group Standard (Amendment) Notice 2024, which took effect on 1 January 2026, and by a further Amendment Notice 2025 that took effect on 30 December 2025. Both notices are published in the New Zealand Gazette and administered by the EPA. Unlike the EU's directly-applicable Regulation (EC) No 1223/2009, the Group Standard is a New Zealand domestic instrument: it borrows the EU's ingredient logic and much of its annex numbering, but it is issued, amended and enforced entirely by the EPA under New Zealand law.
The five ingredient schedules
Ingredient rules sit in Schedules 4 to 8 of the Group Standard. Each one maps closely, but not identically, onto one of the EU Cosmetics Regulation's annexes:
- Schedule 4 - components cosmetic products must not contain. Table 1 mirrors the EU's Annex II prohibited list; Table 2 adds New Zealand-specific prohibitions, including the per- and polyfluoroalkyl substances (PFAS) entry added by the 2024 Amendment Notice.
- Schedule 5 - components cosmetic products must not contain except subject to restrictions and conditions, corresponding to EU Annex III restricted substances, again split into an EU-mirroring table and New Zealand-only additions.
- Schedule 6 - colouring agents cosmetic products may contain with restrictions, corresponding to EU Annex IV, with a Table 2 of additional colouring agents allowed in New Zealand.
- Schedule 7 - preservatives cosmetic products may contain with restrictions, corresponding to EU Annex V, with a similar New Zealand-only additional table.
- Schedule 8 - UV filters cosmetic products may contain with restrictions, corresponding to EU Annex VI.
The split into an EU-mirroring Table 1 and a New Zealand-only Table 2 is how the consolidated text read before the 2024 and 2025 amendments. The amendment notices do not appear to restructure it, but confirm a specific entry against the EPA's current consolidated schedules before relying on its table.
That split into an 'EU-mirroring' table and a 'New Zealand additional' table is the structural detail worth understanding: most entries in Schedules 4 to 8 use the same entry numbers as the corresponding EU annex, which is why a New Zealand record on cosingchecker.com/regulations/nz/ often carries a reference number that lines up with an EU Annex II, III, IV, V or VI entry number. But each schedule also carries entries that exist only in the New Zealand table, added by New Zealand's own decision process rather than copied from Brussels.
The 2026 update, and why it matters for the EU comparison
The Cosmetic Products Group Standard (Amendment) Notice 2024 (New Zealand Gazette 2024-sl388), which commenced on 1 January 2026, is described by the EPA as bringing Schedules 4 to 8 into closer alignment with the EU's positions on prohibited, restricted, colourant, preservative and UV-filter ingredients. It also expanded the standard's scope to non-hazardous products containing a hazardous ingredient, added PFAS to Schedule 4 Table 2 with its own transition timeline, and updated nanomaterial notification and fragrance-standard references (from the IFRA Code of Practice to the IFRA Standards). A second notice, the 2025 amendment (Gazette 2025-sl3889), commenced on 30 December 2025 and made further corrections to Schedule 5, including revised hair-dye limits and CAS numbers, and set the transition dates for homosalate.
For a brand selling the same formulation in both the EU and New Zealand, the practical consequence is that the two rulebooks are not synchronised. New Zealand updates its schedules periodically, in batches, following its own gazette process; the EU updates Annexes II to VI continuously, substance by substance, through individual Commission Regulations. A formulation that is compliant in the EU today can still fail in New Zealand if the relevant New Zealand amendment has not yet caught up, and vice versa for substances New Zealand restricts before the EU does. Checking one jurisdiction's record is not evidence for the other; the two need to be checked separately, ingredient by ingredient.
Worked example: homosalate, a case of New Zealand lagging behind the EU
Homosalate (CAS 118-56-9) is Annex VI entry 3 in the EU. The EU's current limit, in force since 2025, restricts homosalate to a maximum of 7.34% in face products (excluding propellant sprays), with products that do not comply barred from the EU market from 1 January 2025 and from sale from 1 July 2025. The site's New Zealand record for the same substance, Schedule 8 reference 3, currently carries a flat maximum concentration of 10%, unqualified by product type. The 2025 New Zealand amendment sets a transition timeline for homosalate specifically - import and manufacture of non-complying products permitted until 30 June 2027, supply until 30 June 2028, and disposal required by 31 March 2029 - which signals a tightening is under way, but the site's current effective New Zealand record still shows the pre-tightening 10% limit rather than the EU's 7.34% face-product cap. A sunscreen formulated to the EU's 7.34% limit will also satisfy New Zealand's current 10% cap; a sunscreen formulated to New Zealand's 10% cap will not necessarily satisfy the EU limit.
Worked example: PFAS, a case of New Zealand moving ahead of the EU
The opposite pattern shows up with PFAS. New Zealand's 2024 Amendment Notice added per- and polyfluoroalkyl substances as a defined class to Schedule 4 Table 2, with import and manufacture of PFAS-containing cosmetics prohibited from 31 December 2026, supply prohibited from 31 December 2027, and disposal required by 30 June 2028. The EU, by contrast, has no EU-wide, cosmetics-specific PFAS prohibition yet: the proposed universal PFAS restriction is being assessed under REACH by ECHA's Risk Assessment Committee and Committee for Socio-Economic Analysis, with the SEAC draft opinion out for public consultation and EU-wide entry into force not expected before 2027, and possibly later. Some EU member states have moved unilaterally in the meantime - France's national ban on PFAS in cosmetics took effect on 1 January 2026 - but there is no single EU annex entry a formulator can point to yet. Here it is New Zealand's Group Standard, not the EU annexes, that gives a fluorinated-ingredient formulation the more concrete near-term deadline.
Worked example: a substance where the two jurisdictions already match
Most of Schedule 4 does track the EU directly, which is worth showing alongside the two divergent cases above. Butylphenyl methylpropional (BMHCA, commonly called Lilial, CAS 80-54-6) was added to the EU's Annex II prohibited list by Regulation (EU) 2021/1902, as Annex II entry 1666. The site's New Zealand record for the same substance is Schedule 4, reference 1666 - the identical entry number, carried over into the current, 1 January 2026-effective New Zealand schedule. This is the ordinary case: New Zealand's Table 1 entries are keyed to the same numbering as the EU annex they mirror, so once the EPA's periodic update catches up, the two records line up exactly.
Worked example: a colourant listed only in New Zealand's own table
In the pre-amendment consolidated text, Schedule 6 Table 2 - the 'additional list of colouring agents allowed for use in cosmetic products in New Zealand' - is where the EPA's own decisions, rather than EU mirroring, appear directly. Mica (CI 77019, CAS 12001-26-2) is one of the entries there, listed under Schedule 6 reference 1 for products giving shine. On the site's data, mica's CAS number returns no matching entry in the EU's Annex IV colourant list; the record the matching logic surfaces instead (CI 77015, a different aluminium-silicate pigment) does not share mica's CAS number. That is not evidence that mica is prohibited or restricted in the EU - Annex IV entries concern permitted colourants for products marketed as coloured, and a mineral used in that role may or may not appear there under its own CAS number - only that this entry sits in New Zealand's own additional table, and that the site's own EU-annex cross-check turns up no CAS match for it.
How to check a formulation against both rulebooks
The practical workflow is the same one used for any two-jurisdiction check on this site. Look up each ingredient's CAS or EC number on cosingchecker.com/regulations/nz/ to get its current New Zealand schedule reference, status and conditions, sourced from the EPA's own published schedules. Then use cosingchecker.com/market-compare/ to line that record up against the EU annex entry and any other jurisdiction's rule for the same substance side by side. Where the two disagree, or where one has a rule the other does not yet have, cosingchecker.com/market-divergence/ collects that class of case across the full dataset rather than one substance at a time. In every case the record is identity evidence for what a regulator has published under a given CAS or EC number - it is not a safety verdict, and the absence of a New Zealand record for a substance means the site has not matched one, not that the substance is unregulated or permitted.
What the schedule count tells you, and what it does not
The site currently holds 2,913 published New Zealand records, drawn from the EPA's own spreadsheet of Schedules 4 to 8 of the Cosmetic Products Group Standard, most carrying an effective date of 1 January 2026. That figure describes how many rows the EPA's schedules currently contain and the site has matched to an ingredient or substance record - it is a count of published rules, not a count of every substance New Zealand cosmetics law touches, and it will change again at the next gazetted amendment. Anyone relying on a specific entry for a live formulation should still read the current Schedule 4 to 8 text on epa.govt.nz directly; the EPA's own schedules, not any third-party database, are what a New Zealand compliance decision is measured against.
Sources
- EPA New Zealand - Cosmetics substance guidance (Cosmetic Products Group Standard overview) — https://www.epa.govt.nz/hazardous-substances/rules-notices-and-how-to-comply/specific-substance-guidance/cosmetics/
- EPA New Zealand - Cosmetic Products Group Standard 2020, HSR002552 (consolidated, superseded 1 January 2026 - schedule structure and history) — https://www.epa.govt.nz/assets/FileAPI/hsno-ar/APP204297/Cosmetic-Products-Group-Standard-2020-HSR002552-superseded-on-1-January-2026-v2.pdf
- New Zealand Gazette - Cosmetic Products Group Standard (Amendment) Notice 2024, 2024-sl388 (commencement 1 January 2026; PFAS transition dates; schedule and scope changes) — https://gazette.govt.nz/notice/id/2024-sl388
- New Zealand Gazette - Cosmetic Products Group Standard (Amendment) Notice 2024, Amendment 2025, 2025-sl3889 (commencement 30 December 2025; homosalate transition dates; Schedule 5 corrections) — https://gazette.govt.nz/notice/id/2025-sl3889
- European Commission CosIng / cosingchecker.com Annex VI record for Homosalate (EU concentration limit and 2025 compliance dates) — https://cosingchecker.com/annex/vi/vi-3-homosalate/
- cosingchecker.com Annex II record for 2-(4-tert-butylbenzyl)propionaldehyde / Lilial (Regulation (EU) 2021/1902, entry 1666) — https://cosingchecker.com/annex/ii/ii-1666-2-4-tert-butylbenzyl-propionaldehyde/
- ECHA - PFAS restriction proposal under REACH, RAC and SEAC opinion status — https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas
- cosingchecker.com API - jurisdictions list, New Zealand jurisdiction rules, and ingredient jurisdiction cross-checks (live data used for all New Zealand and EU record counts and examples in this article) — https://cosingchecker.com/api/v1/jurisdictions/
About this article
This article is part of the CosIng Checker blog, where we publish guides, notes and practical explainers about EU cosmetic ingredients, Annex II–VI restrictions, warnings, preservatives, UV filters, colorants and related compliance topics.