Selling Cosmetics in California? Don’t Overlook the California Safe Cosmetics Program (CSCP)

nofearljc

Sep 11

3 min read

For cosmetic brands entering the U.S. market, FDA compliance is often the first priority. However, companies selling cosmetic products in California may face additional state-level requirements beyond federal FDA and MoCRA compliance.

One important requirement is the California Safe Cosmetics Program (CSCP), administered by the California Department of Public Health (CDPH).

If your cosmetic product contains certain ingredients identified as hazardous or potentially hazardous, your company may be required to report the product and its ingredients to the State of California.

What Is the California Safe Cosmetics Program (CSCP)?

The California Safe Cosmetics Program implements California laws designed to collect information about potentially hazardous ingredients used in cosmetic and personal care products sold in the state.

Under California's cosmetic reporting requirements, certain companies must report cosmetic products containing ingredients that appear on designated authoritative lists.

These may include substances associated with:

Cancer
Reproductive or developmental toxicity
Other specified health concerns
Certain fragrance and flavor ingredients
Certain fragrance allergens

The California Department of Public Health maintains a CSCP Reportable Ingredients List, which companies should review when determining whether a cosmetic product is subject to reporting.

Does Every Cosmetic Product Need to Be Registered?

No.

CSCP is not a general cosmetic product registration system where every cosmetic sold in California must automatically be registered.

Instead, the reporting requirement is triggered when an applicable cosmetic product contains an ingredient that meets California's reporting criteria.

This distinction is important for companies entering the California market.

A product may be compliant with federal FDA cosmetic requirements while still having a separate California reporting obligation.

What Information May Be Required?

When a product is subject to CSCP reporting, companies may need to provide information such as:

Company and brand information
Product name and product variation
UPC information
Product category and intended use
Manufacturer information
Reportable ingredient information
Product formulation information necessary to identify reportable ingredients

Reported product information is submitted through the California Safe Cosmetics Program reporting system.

Ingredient Screening Should Come Before Filing

Before submitting a CSCP report, the first step should be determining whether the formulation actually contains a reportable ingredient.

This can be more complicated than simply reviewing the ingredient statement printed on the product label.

Depending on the formulation, companies may need to evaluate raw material composition, fragrance components, flavor components, naturally occurring constituents, and other formulation information provided by manufacturers or ingredient suppliers.

California also updates its reporting requirements and Reportable Ingredients List, making ongoing regulatory review important for brands that continue to sell products in the state.

CSCP Is Different From Proposition 65

CSCP reporting should also not be confused with California Proposition 65.

Although both programs address chemicals associated with health concerns, they impose different compliance obligations.

CSCP primarily involves reporting applicable cosmetic products and reportable ingredients to the California Department of Public Health.

Proposition 65, on the other hand, may require a consumer warning when a product causes exposure to a listed chemical at a level requiring a warning.

Therefore, the presence of a particular ingredient may require evaluation under multiple California regulatory frameworks.

California Compliance Goes Beyond FDA and MoCRA

For cosmetic companies selling nationwide, California deserves particular attention.

Federal compliance under FDA and the Modernization of Cosmetics Regulation Act (MoCRA) does not automatically satisfy California-specific requirements.

Before launching or distributing cosmetics in California, companies should consider reviewing:

FDA / MoCRA Compliance → California Ingredient Screening → CSCP Reporting Assessment → Proposition 65 Assessment

Taking these steps before market entry can help identify potential compliance issues before products are distributed.

J&B Food Consulting Can Help

J&B Food Consulting provides regulatory support for cosmetic companies entering and operating in the U.S. market.

Our California cosmetic compliance services can include:

CSCP Reportable Ingredient Screening
Cosmetic Formulation Review
California Safe Cosmetics Program Reporting Support
Proposition 65 Ingredient Screening
California Cosmetic Regulatory Review
FDA / MoCRA Compliance Support
U.S. Cosmetic Label Review

If you are planning to sell cosmetic or personal care products in California, J&B Food Consulting can review your formulation and help determine whether additional California reporting or compliance requirements may apply.

Selling in California? Check your ingredients before your products enter the market.

Contact J&B Food Consulting for a California cosmetic compliance assessment.