Soap & Cosmetic Products Sold in California
This article applies to any product sold in California.
Over the last several years, California passed several Acts that updated their laws covering soap and cosmetics. The California laws now have portions that can apply to any soap or cosmetic product sold in California or to a resident of California.
Essentially, these laws address soap and cosmetic products that contain ingredients that the State of California has deemed to be potentially harmful.1 It’s called the Reportable Ingredients List. Any product that contains one of those ingredients (with some exceptions for small businesses) must report the product to the California Department of Health through their California Safe Cosmetics Reporting Portal
Most of the ingredients are unlikely to be used in handcrafted or small batch soap and cosmetics that use primarily safe and even food-grade ingredients … except fragrances.
Fragrance oils may contain some of the ingredients on the list, but fragrance manufacturers have been phasing out ingredients known to be harmful. If you’re using fragrance oils, your supplier should tell you if there is something you need to report.
However, if you are using essential oils, the story is different. Many essential oils contain one or more of the ingredients on the list that are deemed to be fragrance allergens – or they are themselves considered fragrance allergens. Products that include them will have to be reported.
Who has to report?
If your company has more than $1 million in annual revenue worldwide, you must report any cosmetic that contains any ingredient on the Reportable Ingredients List.
If your company has less than $1 million in annual revenue, you must report any cosmetic that contains fragrance or flavor ingredients or fragrance allergens that are in the Reportable Ingredients List.
IMPORTANT NOTE: The applicable California law defines a cosmetic as “an article for retail sale or professional use intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance.” IT DOES NOT EXEMPT SOAP.
Reportable Fragrance Allergens
The reportable fragrance allergens are the same as (and taken from) the EU regulations which list the fragrance allergens that need to be declared on the label in the EU. There are currently 24 fragrance allergens on the list, and another 54 that will go into effect in 2026. All but 12 are found in one or more essential oils.
A fragrance allergen must be reported when it is present at more than 0.01% (100 parts per million) in a rinse-off cosmetic product or at 0.001% (10 parts per million) in a leave-on product. These are the same limits used for the EU product labels.
It’s a matter of math to determine whether the level of a fragrance allergen in your product requires you to report it. You can use the same math process that is described in the article Fragrance Safety – Using IFRA Standards.
Reporting Deadlines
The deadlines for reporting have passed for everything except the new fragrance allergens on the EU list, which must be reported in California at the same time as they must be on the labels in the EU (July 2026). (You can report them earlier, but it’s not required.)
That means if your product contains any of the fragrance allergens that are currently on the EU list, you are already behind in reporting them in California.
How To Report
Information and a series of videos on how to report can be found on California’s Information for Cosmetic Companies page. You can also find links to additional information on that page. The first step is to create an account and link your company to it.
The information you will need to report a product includes:
- Company name
- Brand name
- Product name, exactly as it appears on product label or package
- Variation name (for example, the color, scent, flavor, or SPF)
- Company’s internal product ID (optional)
- Universal Product Codes (UPC) - this is the 12-digit barcode number
- Product's website address
- Product marketing photo - any photo showing the product in its entirety along with its brand name, product name, and any applicable variant name. Acceptable file types include .png, .jpg, .jpeg, and .webp.
- Product’s intended market (professional use only, general consumers, children, etc.)
- Product’s intended application area (face, hands, etc.)
- Product’s physical form (cream, powder, spray, etc.)
- List of the product’s manufacturers
- Product formulation information from manufacturer(s) and supplier(s) needed to identify all reportable ingredients
A Note About MoCRA
California doesn’t require fragrance allergens to be listed on the product label. In fact, they aren’t allowed to require more label information than the federal regulations.
However, MoCRA WILL require fragrance allergens to be listed on cosmetic product labels in the US. We don’t know yet which fragrance allergens will be required to be listed, but it’s likely that it will initially be the same 24 fragrance allergens that are currently required on labels in the EU, and which must be reported in California.
Any time you spend figuring out the fragrance allergen levels in your products for reporting in California will also help when the FDA releases their list of reportable fragrance allergens.
1 California has determined that any substance on any of the following lists (now or in the future) is considered a “reportable ingredient”:
(B) Chemicals classified by the European Union as carcinogens, mutagens, or reproductive toxicants pursuant to Category 1A or 1B in Annex VI to Regulation (EC) 1272/2008.
(C) Chemicals included in the European Union Candidate List of Substances of Very High Concern in accordance with Article 59 of Regulation (EC) 1907/2006 on the basis of Article 57(f) for endocrine disrupting properties.
(D) Chemicals for which a reference dose or reference concentration has been developed based on neurotoxicity in the federal Environmental Protection Agency’s Integrated Risk Information System.
(E) Chemicals that are identified as carcinogenic to humans, likely to be carcinogenic to humans, or as Group A, B1, or B2 carcinogens in the federal Environmental Protection Agency’s Integrated Risk Information System.
(F) Chemicals included in the European Chemicals Agency Candidate List of Substances of Very High Concern in accordance with Article 59 of Regulation (EC) 1907/2006 on the basis of Article 57(d), Article 57(e), or Article 57(f) of Regulation (EC) 1907/2006 for persistent, bioaccumulative and toxic, or very persistent and very bioaccumulative, properties.
(G) Chemicals that are identified as persistent, bioaccumulative, and inherently toxic to the environment by the Canadian Environmental Protection Act Environmental Registry Domestic Substances List.
(H) Chemicals classified by the European Union in Annex VI to Regulation (EC) 1272/2008 as respiratory sensitizer category 1.
(I) Group 1, 2A, or 2B carcinogens identified by the International Agency for Research on Cancer.
(J) Neurotoxicants that are identified in the federal Agency for Toxic Substances and Disease Registry’s Toxic Substances Portal, Health Effects of Toxic Substances and Carcinogens, Nervous System.
(K) Persistent bioaccumulative and toxic priority chemicals that are identified by the federal Environmental Protection Agency National Waste Minimization Program.
(L) Reproductive or developmental toxicants identified in Monographs on the Potential Human Reproductive and Developmental Effects published by the federal National Toxicology Program, Office of Health Assessment and Translation.
(M) Chemicals identified by the federal Environmental Protection Agency’s Toxics Release Inventory as Persistent, Bioaccumulative and Toxic Chemicals that are subject to reporting under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (42 U.S.C. Sec. 11001, et seq.).
(N) The Washington Department of Ecology’s Persistent, Bioaccumulative, Toxic (PBT) Chemicals identified in Chapter 173-333 of Title 173 of the Washington Administrative Code.
(O) Chemicals that are identified as known to be, or reasonably anticipated to be, human carcinogens by the 13th Report on Carcinogens prepared by the federal National Toxicology Program.
(P) Chemicals for which notification levels, as defined in Section 116455, have been established by the State Department of Public Health or the State Water Resources Control Board.
(Q) Chemicals for which primary maximum contaminant levels have been established and adopted under Section 64431 or 64444 of Title 22 of the California Code of Regulations.
(R) Chemicals identified as toxic air contaminants under Section 93000 or 93001 of Title 17 of the California Code of Regulations.
(S) Chemicals that are identified as priority pollutants in the California water quality control plans pursuant to subdivision (c) of Section 303 of the federal Clean Water Act (33 U.S.C. Sec. 1341) and in Section 131.38 of Title 40 of the Code of Federal Regulations, or identified as pollutants by the state or the federal Environmental Protection Agency for one or more water bodies in the state under subdivision (d) of Section 303 of the federal Clean Water Act (33 U.S.C. Sec. 1341) and Section 130.7 of Title 40 of the Code of Federal Regulations.
(T) Chemicals that are identified with noncancer endpoints and listed with an inhalation or oral reference exposure level by the Office of Environmental Health Hazard Assessment pursuant to paragraph (2) of subdivision (b) of Section 44360.
(U) Chemicals identified as priority chemicals by the California Environmental Contaminant Biomonitoring Program pursuant to Section 105449.
(V) Chemicals that are identified on Part A of the List of Chemicals for Priority Action prepared by the Oslo and Paris Conventions for the Protection of the Marine Environment of the North-East Atlantic.
