California Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (SB312)

Posted December 14, 2020

In Ingredient Disclosure, Product Safety

By: Joe McCarthy, Lab Service Manager/Senior Regulatory Affairs Specialist, email

On September 30, 2020, the California Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 was signed into law by Governor Gavin Newsom.

This new law requires that starting January 1, 2022, a manufacturer of a cosmetic product sold in the state of California shall disclose all of the following information to the Division of Environmental and Occupational Disease Control within the State Department of Public Health:

A list of each fragrance ingredient or flavor ingredient that is included on any of the 22 different Designated Lists defined in the Act.
A list of each EU fragrance allergen that is present in a rinse-off cosmetic product at a concentration at or above 0.01 percent (100 ppm) or in a leave-on cosmetic product at a concentration at or above 0.001 percent (10 ppm).
Whether the cosmetic product is intended for professional use or retail cosmetic use.
The Chemical Abstracts Service (CAS) number for each fragrance, flavor or allergen ingredient that is required to be disclosed.
The Universal Product Code (UPC) for the cosmetic product.

While the California Cosmetic Fragrance and Flavor Ingredient Right to Know Act defines the Designated Lists;

It does not tell you how or where to find the lists.
The lists are often embedded within a much larger regulation which are difficult to navigate.
The lists are in different formats (PDF, xml, html) often without CAS# or specific chemical names.

It probably takes an hour or more to search all 22 Designated List for each ingredient.

Dell Tech Laboratories has created an Excel® based search tool that will allow you to quickly and easily search all of your CAS# against all the Designated Lists and create the required disclosure in minutes instead of hours. With this tool, all the lists can be searched with a single copy & paste of a CAS# or list of CAS#.

You can watch a demo of how the Ingredients Disclosure Search Tool works at this link.

How are you finding & searching the 22 Designated Lists in SB312 for each of the ingredients in your products?

How long is that taking you and will you be ready for January 1, 2022?

Do you know how & where to submit the information to the California Division of Environmental and Occupational Disease Control within the State Department of Public Health?

To get your copy of the Designated List Search Tool for the California Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020

Contact:
Dell Tech
Joe McCarthy, Senior Regulatory Affairs Specialist
jmccarthy@delltech.com
519-858-5024