California updates reportable ingredients list for cosmetics products

On 29 July 2024, the California Department of Public Health (CDPH) published its updated reportable ingredients list (RIL) for cosmetics, adding 29 new ingredients to the list.

Reporting Requirements under California Cosmetics Legislation

The California Safe Cosmetics Act of 2005 mandates manufacturers to report products containing carcinogenic ingredients to the CDPH. The Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 mandates reporting of certain fragrance allergens after 1 January 2022.

Fragrance Allergen Reporting Thresholds

Fragrance allergens must be reported when present in a rinse-off cosmetic product at a concentration at or above 0.01 percent (100 parts per million) or in a leave-on cosmetic product at a concentration at or above 0.001 percent (10 parts per million).

California Safe Cosmetics Program Chemical List

The California Safe Cosmetics Program (CSCP) has developed a list of chemicals, including those reportable under the CA Safe Cosmetics Act and the Cosmetic Fragrance and Flavor Ingredient Right to Know Act. The list is available here as a downloadable spreadsheet and includes a fourth tab labelled "Summary of Updates" which shows all ingredients that have been added to or removed from the RIL since the last update.

Manufacturers of cosmetic products in California must report fragrance allergens in Annex III of EU Cosmetics Regulation No. 1223/2009, as required by EU Detergents Regulation No. 21 648/2004, by 2026 or 2028 at the latest, or at any time.

Manufacturers must disclose identified allergens to the California Department of Public Health by the deadlines set by EU law, which are 2026 or 2028, but manufacturers may submit earlier.