California Safe Cosmetics Online Reporting FAQ
Frequently asked questions about the Online Reporting System
1. Who is required to report under the CA Safe Cosmetics Act?
2. Which products and which ingredients must be reported?
3. How does a company submit a product/ingredient to the California Safe Cosmetics Program?
4. How do I update my company's information in your online reporting system?
5. Can changes be made to a product after it has been submitted?
6. Can I remove a chemical from a previously-submitted product?
7. I received an error message while submitting to the database. What happened and what should I do?
8. Are trade secret (TS) exempt from reporting? What kind of supporting documentation will I need to submit to substantiate my trade secret claim?
The following questions will help determine if you must report under the CA Safe Cosmetics Act:
Does your company make $1,000,000 or more annually in worldwide aggregate cosmetic sales?
Does your company's name appear on the label of a cosmetic product sold in California after January 1, 2007?
Do any of these cosmetics contain an ingredient identified as a known or suspected human carcinogen or reproductive toxicant?
Your company is subject to the mandatory reporting requirements of the CA Safe Cosmetics Act if you answered yes to all three of the above questions. Please see our Cosmetics Companies web page for more information.
Any cosmetic product sold in California after January 1, 2007, which contains an ingredient known or suspected of causing cancer or reproductive harm to humans must be reported.
More information on this topic can be found on our Cosmetic Companies web page, including the following:
Cosmetics companies should report electronically using the California Safe Cosmetics Program online reporting system. Both the online reporting system and instructions detailing the submission process are available on our Cosmetics Companies web page.
You can edit company contact information, submitter information or a cosmetic firm's profile online.
To edit your company's information in the online reporting system:
Log in to your account.
Click the "Update company information" link.
Make the desired changes.
Provide an electronic signature and hit "Submit" to override your original entry.
Yes, you can edit your submissions online. Most elements of a product submission can be edited, with the notable exceptions of the Chemical Name and CAS#.
To edit a product entry:
- Log in to your account.
- Click the "Add/Update Products" link.
- Find the entry in question from your submitted product list, and click on the "Edit" button to access your submission.
- Click through the submission, making the desired changes to each screen. NOTE: Hitting the "Next" button at the bottom of each page saves the data on that page. Any changes made to a page will overwrite existing data when you hit "Next".
- Provide an electronic signature on the Signature Page and hit "Submit" to create a record of who made the changes to the record in question.
Yes, you can remove a chemical ingredient from a product IF that product has been reformulated and no longer contains the chemical in question. Follow the instructions provided for editing a submission (see above). Use the "Remove" button instead of the "Edit" button to make this change.
The most common reason for receiving an error message while submitting data is that you have been timed out of your account. This security measure occurs after 20 minutes of inactivity. Hitting the "Next" button at the bottom of each page saves the data on that page, so you should only have lost information on the screen you were viewing when you were timed out.
If you get an error message, try the following:
Close your web browser completely.
Relaunch your web browser and re-log in to your account.
Click the "Add/Update Products" link.
Find the entry in question from your submitted product list, and click on the "Edit" button to access your submission. Click through the submission screens using the Next button, reviewing your partially-entered data and filling in any remaining fields.
Provide an electronic signature and hit the "Submit" button on the Submission page to complete the online submission for this product.
If the above steps do not resolve your problem, contact us at: email@example.com. Include both the error message you received and a detailed description of what you were doing when you received the error in the body of your email.
TS information is not exempt from reporting to the California Department of Public Health (CDPH). However, CDPH cannot make any confidential and/or TS information available to the public unless the outcome of an official investigation deems the information is not confidential and/or TS. Companies declaring TS for any ingredient must submit supporting written documentation to justify this designation.
For purposes of the Safe Cosmetics Act, TS designation is determined "pursuant to the procedure established in Part 20 and Section 720.8 of Part 720 of Title 21 of the Code of Federal Regulations" (California Health and Safety Code § 111791). The CSCP requires documentation from the US Food and Drug Administration (US FDA) granting TS status, indicating that the information so designated is indeed TS under federal law.
The chemical(s) must also meet the definition of "trade secret" under California law. Under the California Uniformed Trade Secrets Act, "trade secret" is defined as information, including a formula, that (1) derives independent economic value from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) is the subject of efforts that are reasonable under the circumstances to maintain its secrecy. Note that ingredients listed on the label of products sold to the public are "known to the public" and therefore would not meet the definition of a TS.
In order for an ingredient to qualify as a TS, you must (1) provide written documentation from the US Food and Drug Administration (US FDA) granting the ingredient TS status and (2) provide proof that the ingredient(s) meets the Uniformed Trade Secrets Act's (California Civil Code § 3426.1) definition of "trade secret." Documentation must be submitted for each ingredient you are seeking to designate a TS.
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