While the Modernization of Cosmetics Regulation Act (MoCRA), enacted on December 29, 2022, introduced major updates to the US cosmetic regulatory framework. It is important to note that individual states retain the authority to enact their own laws under the principle of federal preemption. In particular, MoCRA does not address ingredient compliance, leaving ingredient restrictions to individual states.
Among these, California stands out as one of the most stringent jurisdictions for cosmetic regulation, with several laws governing cosmetic formulation and labelling. Among the key legislation measures, there are Proposition 65, California Safe Cosmetics Program, CARB VOC limits, California Toxic-Free Cosmetics Act, and PFAS Act.
Proposition 65: list of chemicals and related warnings
Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, was passed as a ballot initiative in November 1986. Proposition 65 requires the State of California to publish and maintain a list of chemicals known to cause cancer, birth defects, or other reproductive harm. The list is reviewed regularly, with its last revision published in January 2025, including over 900 chemicals.
Under Proposition 65, businesses must provide clear and reasonable warnings before knowingly exposing individuals to listed chemicals through consumer products, including cosmetics. Such warnings are required unless the concentration of these substances in the formulas falls below established safety thresholds.
California Safe Cosmetics Program
The California Safe Cosmetics Act of 2005 (CSCA) requires manufacturers, packers, and distributors of cosmetic products sold in California to report to the California Department of Public Health (CDPH) any products containing ingredients known or suspected to cause cancer, birth defects, or other reproductive harm.
Part of the same framework is the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (CFFIRKA, which mandates reporting of cosmetic products containing specific fragrance and flavor ingredients. This Act came into effect on 1 January 2022.
The list of reportable ingredients is updated regularly, with the most recent update issued in June 2025.
CARB VOC limits: California Consumer Products Regulations
The California Air Resources Board (CARB) regulates the amount of volatile organic compounds (VOCs) allowed in consumer products, including cosmetics. The VOC limits vary by product category and apply to items such as hair styling products, hair shine sprays, mousses, nail polish removers, and personal fragrance products.
The variation in allowable VOC content across product categories is significant, ranging from as low as 2% in non-aerosol hair styling products to as high as 50% in hair shine products. Beauty brands should carefully review their product labels to ensure that each item is correctly classified and compliant with the applicable regulatory requirements.
California Toxic-Free Cosmetics Act
Effective 1 January 2025, the Toxic-Free Cosmetics Act (Assembly Bill 2762) prohibits the use of 24 specified ingredients in cosmetic products sold in California. Companies should carefully review product formulations to ensure compliance with the TFCA and avoid the use of banned substances.
California PFAS-Free Cosmetics Act
The PFAS-Free Cosmetics Act (AB 2771, Friedman) bans the sale of personal care and beauty products containing any intentionally added per- and polyfluoroalkyl substances (PFAS) in California. Commonly referred to as “forever chemicals”, PFAS are highly persistent in the environment and have been linked to adverse health effects.
The law applies broadly to all cosmetic products – defined as items intended for application to the body for cleansing, beautifying, altering appearance, or promoting attractiveness.
The Act came into effect on 1 January 2025.
Obelis specialises in helping brands ensure compliance global cosmetic regulations. We assist with formula and label reviews as well as reporting under MoCRA and California’s specific requirements.
Chiara Lai
Regulatory Intelligence and Innovation Department
21/11/2025
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