United States - Cosmetics
US compliance requirements for cosmetics
Products applied to the body for cleansing or beautification. Governed primarily by dedicated cosmetics law in every market — the entries here are only the general-safety layer around that sector regime.
For example: face cream, shampoo bar, lipstick, essential oil blend.
IMPORTANT CAVEAT: the EU Cosmetics Regulation 1223/2009 (responsible person, safety assessment, Product Information File, CPNP notification, ingredient labelling) is the primary law and is beyond this dataset's electronics focus — flag as 'additional sector rules apply'. The UK has an equivalent retained Cosmetics Regulation (notification via SCPN). US: cosmetics are regulated by the FDA under the FD&C Act as amended by MoCRA (facility registration, product listing, adverse-event reporting) — also beyond this dataset; note that cosmetics are expressly excluded from the CPSC's 'consumer product' definition, which is why us-cpsa-general and us-cpsia are not listed. Prop 65 still applies to cosmetics sold in California. Medicinal or therapeutic claims (treats eczema, SPF drugs in the US) move the product into drug regulation — out of scope. Children's play make-up must satisfy toy safety law in the EU/UK on top of cosmetics law (hence the forChildren additions) — verify. Powered beauty devices (LED masks, facial brushes) are electronics — use the consumer-electronics category for the device. REACH substance duties still apply to cosmetic ingredients, though most human-health restrictions are handled by cosmetics law — verify overlaps.
Base requirements1 instruments
California law requiring businesses to give a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical on the state's Proposition 65 list, and prohibiting knowing discharges of listed chemicals into drinking water sources. It is a warning law, not a ban — products containing listed chemicals may still be sold if properly warned.
Key obligations
- 01Provide a clear and reasonable warning before knowingly and intentionally exposing anyone in California to a chemical listed under Proposition 65, unless the exposure is low enough to qualify for an exemption.source
- 02Do not knowingly discharge listed chemicals into sources of drinking water in California.source
- 03Track the chemical list: OEHHA maintains the list, which must be updated at least once a year and has grown to include over 800 chemicals (naturally occurring and synthetic) listed for cancer, birth defects or other reproductive harm since first publication in 1987. The current list is dated December 8, 2025.source
- 04Once a chemical is newly listed, businesses have 12 months before the warning requirement takes effect for that chemical.source
Documents you will need
Deduplicated across the regulations above
- Warning label / sign artworkNo certificate or government filing is required; compliance is demonstrated by the warning itself (label, shelf sign/tag, or website warning for internet sales) meeting the content and transmission methods of 27 CCR Article 6.source
- Written notice to retail sellersThe regulations allocate responsibility along the supply chain: manufacturers/suppliers can discharge their duty by providing a warning or a written notice to the retail seller under 27 CCR 25600.2(b) and (c); for internet purchases before January 1, 2028, a retailer is not responsible for posting an updated short-form warning online until 60 calendar days after receiving an updated warning or written notice.source
Frequently asked
Does a Proposition 65 warning mean the product is banned or unsafe?+
No. Prop 65 does not ban any product — it is a right-to-know law. A warning means the business believes the product can expose Californians to a listed chemical above the level where a warning is required (or the business is warning out of caution without measuring exposure).
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