Federal

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Menstrual Products Right to Know Act

Congresswoman Grace Meng’s office reintroduced the Menstrual Products Right to Know Act, with Representative Anna Paulina Luna as the Republican co-lead. The bill proposes amending the Federal Food, Drug, and Cosmetic Act to deem certain menstrual products “misbranded” if their labeling does not list all components of the finished product. The legislation requires manufacturers of tampons, pads and other products to disclose each component on the label. Components should be listed in order of predominance by weight, using standardized or clearly identifiable names, with labeling updated within eighteen months of any formulation change. The bill also defines key terms and established federal preemption rules while preserving existing state laws and allowing applications for exemptions. The provisions were set to apply to products manufactured eighteen months after enactment.

FDA Guidance Document

The U.S. Food and Drug Administration released new draft guidance in October 2025 to update the oversight of menstrual products. The guidance document was open for public comments through January 16, 2026. This draft will replace the FDA’s 2005 guidance and responds to recent congressional direction and growing public interest in ingredient transparency and contaminant evaluation. The draft guidance provides the FDA’s recommendations for performance testing, labeling and information to include in premarket notification (510(k)) submissions, when required, for tampons, pads and menstrual cups. The updated recommendations are intended to promote consistency, transparency and clearer expectations for manufacturers.

Key updates include recommendations specific to menstrual cups, full ingredient disclosure on the outer packaging of all menstrual products and expanded evaluation of potential contaminants. For tampons, the guidance also clarifies recommended methods for assessing Toxic Shock Syndrome (TSS) risk, impacts on vaginal microflora and non-clinical bench testing.

Although nonbinding, the draft guidance clarifies how manufacturers should approach product testing, labeling and, where required, 510(k) submissions. It also reinforces existing obligations under device labeling and quality system regulations. Collectively, these updates reflect an effort to strengthen transparency, standardize testing and align regulatory recommendations with evolving scientific understanding and consumer expectations.

State

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State legislatures across the country are entering 2026 with a sharpened focus on ingredient transparency, chemical safety and life-cycle accountability for consumer products. For manufacturers of menstrual products and diapers and companies producing reusable textiles, this year will bring a set of bills that could reshape labeling norms, supply chain governance and extended producer responsibility frameworks.

Virginia: HB 998

Virginia House Bill 998, introduced in January 2026, would establish new ingredient labeling and chemical restrictions for menstrual products sold in the Commonwealth. The bill applies to products such as tampons, pads and menstrual cups, whether disposable or reusable. Under the proposal, manufacturers would be required to disclose all ingredients present in menstrual products on product packaging in a manner that is visible and easy for consumers to understand. The bill adopts a broad definition of “ingredient,” including intentionally added substances as well as fragrance, colorant components and certain breakdown products that have a functional effect.

The legislation would also prohibit the presence of specified “restricted substances” in menstrual products. These substances include heavy metals (such as lead and mercury), certain preservatives and plasticizers, formaldehyde, triclosan, talc, specific parabens and per- and polyfluoroalkyl substances (PFAS). Restricted substances would be banned if intentionally added at any level, or if present above a threshold set by the Virginia Department of Health. The Department would be required to establish the lowest level that can be feasibly achieved and to review those limits every five years.

Pennsylvania: SB 1127 MP Labeling

Introduced December 29, 2025, SB 1127 would add comprehensive ingredient disclosure rules to the state’s drug, device and cosmetic law. The bill requires manufacturers of disposable menstrual products (including pads, tampons, liners and similar items) to print a plain, conspicuous, ingredient list in order of predominance on the package. Ingredients must be identified using standardized or common chemical nomenclature. Updates to labels must occur whenever ingredients change.

The bill contains special provisions for fragrance disclosure: fragrance components generally do not need to be listed unless they are designated fragrance allergens (the bill includes a statutory list) or are determined by the Consumer Advocate to present a safety concern at certain concentrations. Ingredient information must also be posted on a publicly accessible website. Violations are subject to fines of up to $1000 per violation.

Utah: Draft Bill on MP Labeling

This draft legislation would require manufacturers of menstrual products sold in Utah to list covered substances, defined as lead, cadmium, arsenic and any intentionally added ingredient on the package, beginning January 1, 2027. The disclosure must be:

• Placed on the outside of the package
• Printed in a legible and conspicuous format
• Ordered by predominance by weight (with flexibility for substances present below 1%)

The bill defines menstrual products broadly, covering both disposable and reusable items. The Department of Health would implement rules overseeing label format and compliance. The measure focuses specifically on chemical transparency, rather than broader regulatory obligations.

Massachusetts: HB 2375/SB 2641 MP Labeling

Massachusetts’ legislation would require manufacturers of menstrual products sold in the Commonwealth to list all intentionally added ingredients on packaging in order of predominance. It also requires manufacturers to publish the same ingredient list online in an electronically readable format.

Manufacturers must update package labels within 18 months of an ingredient change and update online disclosures within two months. Violations are subject to civil fines up to $1000. The bill applies to all menstrual products, including disposables and reusables. The House version slightly differs and still contains additional provisions. 

California: AB 405 (Addis), the Fashion Environmental Accountability Act of 2026

AB 405 would create a wide-ranging environmental due-diligence regime for fashion sellers operating in California with over $100 million in annual gross receipts. Its scope includes manufacturers, importers and private-label fashion entities, but does not apply to sellers of used goods or most multibrand retailers. Key provisions include:

Environmental Due Diligence Requirements

Fashion sellers must implement due diligence aligned with OECD guidelines, including:

• Identifying and mitigating significant ecological and societal risks across supply chains
• Mapping suppliers from Tier 1 through Tier 4 on phased timelines (2027–2032)
• Engaging stakeholders and documenting mitigation and remediation efforts

Greenhouse Gas Emissions Disclosure

Sellers must:

• Establish quantitative GHG baselines and Science Based Targets–aligned emissions-reduction pathways across scopes 1, 2, and 3
• Report annually on emissions and target compliance
• Undergo independent verification at least every two years

Chemical Management and Wastewater Oversight

Beginning January 1, 2028, sellers must ensure that significant Tier 2 dyeing, finishing, printing and washing suppliers undertake wastewater testing, chemical inventories and compliance checks. Failure to demonstrate adequate progress on wastewater remediation after 2029 constitutes a violation.

Annual Environmental Due Diligence Report

Starting July 1, 2027, companies must file a public, independently verified report containing:

• GHG emissions data
• Supply chain mapping status
• Material volume disclosures
• Chemical and wastewater data
• Actions taken to address identified environmental risks

Penalties and Enforcement

Violations may incur civil penalties up to 2% of annual revenue, with penalty funds directed to a new Fashion Environmental Remediation Fund for environmental benefit projects. While the bill targets the fashion industry rather than hygiene products, it may influence companies producing textile-based reusable menstrual products or diaper covers that fall within the statutory definitions of “fashion goods.”

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Wrap Up

Together, these bills illustrate a clear policy trend: states are no longer limiting themselves to voluntary guidance or basic product safety rules. Instead, they are increasingly mandating comprehensive transparency, chemically specific disclosure and life-cycle environmental accountability. For manufacturers of menstrual products and diapers, the priority in 2026 will be to monitor these developments closely, assess cross-state compliance implications and anticipate a future regulatory landscape in which detailed ingredient reporting and supply chain documentation are essential elements of market access.