California Safe Cosmetics Act (CSCA) Reporting & CSCP Registration
Cosmetic products distributed in California are subject to ingredient reporting requirements enforced by the California Department of Public Health (CDPH) — separate from, and in addition to, your federal FDA obligations under MoCRA.
Companies must report potentially hazardous ingredients present in cosmetic products under California’s cosmetic ingredient disclosure laws. The California Safe Cosmetics Program (CSCP) collects this information and publishes it, so consumers and salon professionals anywhere in the country can look up the ingredients in the products they use.
Two laws create the obligation: the California Safe Cosmetics Act of 2005 (CSCA) and the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (CFFIRKA). Both are administered through the CSCP, and both report into the same public database.
If you manufacture, distribute or sell cosmetic products in California, you need to establish whether your formulas contain ingredients on the Reportable Ingredient List — and if they do, report them.
Who is required to report
Reporting is required when all three of the following apply to your company:
- Your company has worldwide aggregate cosmetic sales of $1,000,000 or more per year.
- Your company’s name appears on the label of a cosmetic product sold in California on or after 1 January 2007.
- One or more of your cosmetic products contains an ingredient on the CSCP Reportable Ingredient List.
Below the threshold? If your cosmetic sales are under $1 million worldwide, CSCA reporting does not apply — but your federal MoCRA facility registration and product listing obligations still do. The two regimes are independent of each other.
The two California laws, in brief
California Safe Cosmetics Act (CSCA)
Enacted in 2005 and administered by the CSCP within CDPH. It requires companies to report cosmetic products sold in California that contain ingredients known or suspected to cause cancer, birth defects or other reproductive harm.
Cosmetic Fragrance and Flavor Ingredient Right to Know Act (CFFIRKA)
Enacted in 2020 as SB 312, with reporting effective 1 January 2022. It extends disclosure to fragrance ingredients, flavourings and fragrance allergens appearing on designated chemical lists, using the same CSCP reporting portal and public database.
California CSCA vs federal MoCRA — what’s the difference?
These are the two obligations cosmetic companies most often confuse. Registering with the FDA under MoCRA does not satisfy California, and reporting to California does not satisfy the FDA. Most brands selling nationally need both.
| California CSCA / CFFIRKA | Federal MoCRA | |
|---|---|---|
| Regulator | California Department of Public Health (CSCP) | U.S. Food and Drug Administration |
| Applies to | Cosmetic products sold in California | Cosmetic products marketed anywhere in the U.S. |
| What is submitted | Products containing listed reportable ingredients, reported ingredient by ingredient | Facility registration and product listing |
| Sales threshold | $1,000,000+ worldwide aggregate cosmetic sales | No reporting threshold (limited small-business exemptions apply) |
| Is the data public? | Yes — published in the searchable CSCP database | No — held by FDA, not publicly searchable |
| Ongoing duty | Report new products, reformulations and discontinuations as they occur | Biennial renewal of registration and listing |
Which products and ingredients are covered
All cosmetic products sold in the State of California fall within the scope of CSCA and CFFIRKA reporting. What triggers an actual report is the formula, not the product category.
The CSCP maintains a consolidated list of chemicals compiled under the criteria set out in the California Health and Safety Code. It covers ingredients reportable under the Safe Cosmetics Act together with the fragrance and flavour ingredients reportable under CFFIRKA since 1 January 2022. Every product sold in California has to be checked against that list, formula by formula.
Deadlines and enforcement
All cosmetic products containing reportable ingredients sold in California after 1 January 2022 must be reported — regardless of when they were manufactured. Responsibility sits with the company whose name appears on the label, not with the contract manufacturer or the retailer.
CDPH inspectors can prohibit the sale of products that are not in compliance, which in practice means stock pulled from shelves and distribution interrupted while the reporting is sorted out.
When do you have to report?
California does not set a filing window. Health & Safety Code section 111792 requires the information to be provided “on a schedule … as determined by the division”, and CDPH’s guidance to companies is that reporting should be done on a continuous basis, for new products and reformulations alike.
In practice that means there is no grace period. A reportable product is reportable from the moment it goes on sale in California — so a company that launches without a reporting process in place is out of compliance from day one, not from some later deadline.
The programme fixes dates in only a few places:
- Products sold in California after 1 January 2022 must be reported, regardless of when they were manufactured.
- When CDPH updates the Reportable Ingredients List, companies have six months to comply with the additions.
- EU-listed fragrance allergens follow the EU timelines — 2026 and 2028 — and may be reported earlier.
- Once submitted, a product appears in the public database within about 24 hours.
How LMG handles your CSCP reporting
We provide end-to-end support, from identifying reportable ingredients in each formula through to publishing your data to the public database.
We create an account for your company in the California Safe Cosmetics Reporting Portal.
We review each product formulation and identify the ingredients that trigger reporting under CSCA and CFFIRKA.
We add the applicable products and their formulation details to the portal.
We submit the report and send you the public database link showing your product details.
After submission
You can verify your products at any time on the California Safe Cosmetics Program public database.
We monitor regulatory updates to the CSCP and alert you to changes that affect your reporting obligations. When a formula changes, a product is reformulated or a line is discontinued, we update the database entry for you.
Frequently asked questions
Does FDA MoCRA registration cover California reporting?
No. MoCRA is a federal requirement administered by the FDA; CSCA and CFFIRKA are California state laws administered by CDPH. They are separate filings with different scopes, and complying with one does nothing for the other. A brand selling nationally normally needs both.
My company sells less than $1 million a year. Do I still report?
No. The $1,000,000 worldwide aggregate cosmetic sales threshold is one of three conditions that must all be met before CSCA reporting applies. Your federal MoCRA obligations are unaffected by your sales volume.
We are a foreign manufacturer. Does California apply to us?
The duty to report falls on the company whose name appears on the product label of cosmetics sold in California. If that is your company, the obligation applies regardless of where you are based.
What happens to the information we report?
It is published in the California Safe Cosmetics Program public database, where consumers, retailers and salon professionals can search it by product or by company.
Do we have to report again if we reformulate a product?
Yes. Reporting is an ongoing obligation. New products containing reportable ingredients, changes to a reported formula, and discontinued products all need to be reflected in the database.
Who is responsible if a contract manufacturer makes our products?
The company whose name is printed on the label carries the reporting responsibility, not the contract manufacturer.
Is there a deadline to report a new product?
Not a fixed one. California sets no filing window; CDPH asks for reporting on a continuous basis. The obligation applies as soon as a reportable product is on sale in California, so the practical answer is to report before launch rather than after it. The one firm clock is the six months companies get to comply when the Reportable Ingredients List is updated.
CSCP reporting fees
Fixed fees, quoted up front. LMG has not increased its service fees since 2009.
One-time. We create and configure your company account in the California Safe Cosmetics Reporting Portal.
Per product. Formula review against the Reportable Ingredient List, data entry and submission to CSCP.
No hidden charges. If a product turns out to contain no reportable ingredients, there is nothing to file and nothing to pay for it.
Not sure whether your products are reportable?
Send us your formulations and we will tell you which products trigger California reporting — and handle the filing if they do. Trusted by manufacturers in 150+ countries since 2009.
Talk to a specialist MoCRA registration