The California Safe Cosmetics Program (CSCP), established in 2005, is a regulatory framework aimed at ensuring the safety of cosmetics sold in California. As the first state in the U.S. to implement such regulations, California requires cosmetic brands to report any ingredients that may pose a risk to consumer health. Therefore, in this article, UCC will provide you with information related to the California Safe Cosmetics Program.
1. Introduction to the California Safe Cosmetics Program
1.1. Definition
The CSCP oversees the safety of cosmetics by ensuring that companies disclose potentially hazardous ingredients. Consequently, California requires companies to report ingredients deemed dangerous or harmful. These ingredients may also appear under other safety regulations, such as:
- Proposition 65 (The Safe Drinking Water and Toxic Enforcement Act of 1986).
- Chemicals recognized by the Environmental Protection Agency (EPA), Center for the Evaluation of Risks to Human Reproduction (CERHR), and the International Agency for Research on Cancer (IARC).
1.2. How the Program Works
The program mandates that cosmetic brands disclose any harmful or potentially hazardous ingredients. Therefore, companies must continuously update their ingredient lists as product formulations change. If any harmful chemicals are detected, these must be disclosed on product labels. This requirement applies to all cosmetic products sold in California from January 1, 2022, regardless of their production date.
2. Key Aspects of the California Safe Cosmetics Program
2.1. Definitions of Fragrance and Flavor Ingredients
Fragrance and flavor are essential components in many cosmetic products. However, they must be reported under the CSCP if they appear on the Reportable Ingredients List. Specifically, the definition of these ingredients includes:
- Fragrance Ingredients: Any substance or mixture of compounds used to produce a fragrance or eliminate odor. Specifically, cosmetic companies often include these ingredients in products to create a pleasant scent or mask undesirable odors.
- Flavor Ingredients: Any substance or mixture of compounds used to create or enhance flavor. In addition, these ingredients play a crucial role in improving the taste of cosmetic products. Furthermore, they must be disclosed if they are included in the Reportable Ingredients List, ensuring transparency and consumer safety.
Companies must report these ingredients if they include them in any cosmetic product sold in California after January 1, 2022.
2.2. Regulations on Fragrance and Flavor Ingredients under the CSCP
The California Safe Cosmetics Program requires companies to disclose all ingredients on the Reportable Ingredients List, including fragrance and flavor components, regardless of their concentration in the product. Furthermore, when a new ingredient is added to the list, companies must report it within six months.
Furthermore, if a company considers the fragrance or flavor ingredient a trade secret, it does not need to disclose it under the California Public Records Act, as long as it is not on the Reportable Ingredients List. However, companies cannot reveal the quantity or method of formulation.
2.3. Fragrance Allergens
Fragrance allergens, a subset of ingredients on the Reportable Ingredients List, have additional reporting requirements. Companies must disclose these ingredients if they are present in a product at the following concentrations:
- For rinse-off products: Concentration ≥ 0.01% (100 parts per million).
- For leave-on products: Concentration ≥ 0.001% (10 parts per million).
Common fragrance allergens, for example, include:
- Cinnamal
- Hydroxycitronellal
- Limonene
3. Reporting Process for the California Safe Cosmetics Program
Cosmetic companies must report their products through the California Safe Cosmetics Reporting Portal. Before logging into the portal, companies need to gather essential information, such as:
- Company name
- Brand name
- Product name (matching the label)
- Product code and additional details like images and supplier information.
Once the list of Reportable Ingredients is updated, companies have six months to complete their reporting process.
4. Conclusion
The California Safe Cosmetics Program helps safeguard consumer health by ensuring that companies identify and disclose harmful ingredients in cosmetics. Therefore, cosmetic companies must stay vigilant about updating their product formulations and ingredient lists to comply with CSCP regulations.
Should you have any questions or require assistance with compliance, please do not hesitate to contact UCC for expert guidance.
For more information: FDA Cosmetic Color Additives: Ensuring Safety and Quality
