California Bans Trisodium NTA in Cosmetics Starting 2027: Two Months to Comply

Beginning January 1, 2027, California will prohibit the sale of cosmetic products containing intentionally added Trisodium NTA (trisodium nitrilotriacetate). With the deadline two months away, brands selling into California should review their formulations now.

## AB 496 Adds 26 Banned Ingredients

In 2020, California enacted the Toxic-Free Cosmetics Act (AB 2762), banning ingredients such as formaldehyde, mercury, and certain PFAS from cosmetics. In October 2023, Governor Gavin Newsom signed AB 496, which added 26 more ingredients to the list, including Trisodium NTA (CAS 5064-31-3). Most of the newly added substances are already banned in cosmetics in the European Union.

Trisodium NTA is a chelating agent that binds metal ions to stabilize products, and it has been used in cleansers and shampoos. California's Office of Environmental Health Hazard Assessment (OEHHA) also lists its monohydrate form as a carcinogen under Proposition 65.

## Not Just Sales: Holding Inventory Is Also Prohibited

The law goes beyond retail sales. Health and Safety Code §108980 prohibits anyone from manufacturing, selling, delivering, holding, or offering for sale a cosmetic product containing the intentionally added ingredient. Inventory sitting in California warehouses or stores after January 1, 2027 may also be affected, so companies should review distribution stock as well.

## Exception for Unintentional Trace Impurities

Not every detection is a violation. Subdivision (d) of the same section provides that a technically unavoidable trace quantity does not violate the law if the product was made through processes intended to comply, and the trace stems from impurities in natural or synthetic ingredients, the manufacturing process, storage, or migration from packaging.

However, if Trisodium NTA is present in a raw material for a functional purpose, such as chelation, it may be treated as intentionally added. In addition, Proposition 65 applies regardless of intent: if daily exposure exceeds the safe harbor level of 70 µg/day, a warning label is required.

## Compliance Checklist

- Screen all formulations and raw material specifications for Trisodium NTA

- If detected, obtain written confirmation and a COA from the supplier stating it is a byproduct or impurity

- If it serves a functional purpose, reformulate with an alternative before 2027

- Calculate Prop 65 exposure and keep supporting documentation

- Review inventory held in California

California is often seen as a leading indicator for U.S. cosmetics regulation, and similar legislation may follow in other states. With the effective date approaching, companies should confirm product-by-product applicability with a regulatory expert as soon as possible.

References: California Health & Safety Code §108980; OEHHA Proposition 65 List