California Safe Cosmetics Act Reporting (CSCAR)

The California Safe Cosmetics Act of 2005 (CSCA) requires covered companies to report cosmetic products sold in California that contain ingredients identified as causing cancer or reproductive toxicity under California law and specified authoritative sources. The California Department of Public Health administers the reporting program through the California Safe Cosmetics Program.

CSCAR is a practical shorthand for California Safe Cosmetics Act reporting. California's official program is the California Safe Cosmetics Program (CSCP), and companies submit required information through the California Safe Cosmetics Reporting Portal.

For CSCA reporting, CDPH states that a company is subject to mandatory reporting when it has at least $1,000,000 in annual worldwide aggregate cosmetic sales, its name appears on the label of a cosmetic product sold in California, and the product contains a reportable ingredient. The separate CFFIRKA fragrance and flavor reporting law has different criteria and should be evaluated separately.

CDPH maintains a Reportable Ingredients List covering ingredients reportable under the California Safe Cosmetics Act and the Cosmetic Fragrance and Flavor Ingredient Right to Know Act. The list is broader than the Proposition 65 list alone and is updated when relevant authoritative lists change.

If a cosmetic product is sold in California, the reporting rules can apply regardless of whether the sale occurs through a physical retailer, a brand website, or another e-commerce channel. The key issue is whether the product is sold in California and meets the applicable reporting criteria.

No. California Safe Cosmetics reporting is a California state requirement administered by CDPH. MoCRA facility registration and cosmetic product listing are federal FDA requirements. A company can have obligations under both systems at the same time.

CDPH's reporting checklist includes company name, brand and product names, product variation, UPC, website, marketing image, intended market and use, physical form, manufacturer information, and formulation information needed to identify reportable ingredients. The exact fields depend on the reporting law and product.

CDPH instructs companies to report on a continuous basis for new products and product reformulations. Companies should also update previously submitted information when reportable ingredients or other relevant product information changes.

The Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (CFFIRKA) requires reporting of specified fragrance ingredients, flavor ingredients, and fragrance allergens in cosmetics sold in California. It became effective January 1, 2022 and uses designated hazard lists and allergen criteria that are separate from the original CSCA sales-threshold framework.

CDPH updated its guidance for 56 additional fragrance allergens. Products newly introduced to the California market after July 31, 2026 that contain one or more of those allergens must be reported when the applicable concentration threshold is met. CDPH provides a later transition date for products that were already on the California market before July 31, 2026.

Under California Health and Safety Code section 111792.6, covered fragrance allergens are reportable when present at or above 0.01 percent (100 ppm) in rinse-off cosmetics or at or above 0.001 percent (10 ppm) in leave-on cosmetics.

Proposition 65 and California Safe Cosmetics reporting are separate compliance programs. Proposition 65 focuses on warnings for significant exposures to listed chemicals. The California Safe Cosmetics Program collects product ingredient information, and its reportable ingredient framework includes Proposition 65 chemicals as well as chemicals identified through other authoritative lists.

No. The $1 million annual worldwide aggregate cosmetic-sales threshold is part of the original CSCA reporting framework. CDPH's criteria for CFFIRKA fragrance and flavor reporting do not use that same sales threshold, so smaller companies may still have CFFIRKA reporting obligations.

Yes. We can review product and formulation information, screen against the current CDPH Reportable Ingredients List, organize required product data, prepare portal submissions, and support updates for new products and reformulations within the agreed scope.

Turnaround depends on the number of products, the completeness of formulation and supplier information, and whether reportable ingredients require additional verification. Once the necessary product data is complete, we can confirm a case-specific turnaround estimate.

Send your company and brand information, products sold in California, complete formulations or supplier ingredient disclosures, product names and variants, UPCs when available, manufacturer details, and any existing California Safe Cosmetics reporting records. We will review the scope and identify which products may require reporting.