When MoCRA came into force, it marked the biggest change to U.S. cosmetic regulation in decades. For many manufacturers, it felt like the last major hurdle before entering the U.S. market.
It wasn’t.
Unlike the European Union, where cosmetic requirements are largely harmonised across Member States, the U.S. allows individual states to introduce their own legislation. California has taken that opportunity further than any other state.
In hindsight: MoCRA establishes the federal framework. California builds on it.
Today, compliance in California extends beyond federal requirements to include ingredients, reporting obligations, consumer warnings and product presentation.
Compliance no longer begins and ends with the formula
Ingredient compliance is where most manufacturers begin.
California expects them to go further.
Through legislation such as the California Toxic-Free Cosmetics Act and the California PFAS-Free Cosmetics Act, manufacturers must also consider additional restrictions on intentionally added substances. For companies already selling in Europe, much of this direction will feel familiar.
Compliance Doesn’t End at Market Entry
One of the biggest misconceptions about cosmetic compliance is that it ends once a product is launched.
In reality, compliance is an ongoing responsibility in many markets. California, for example, requires manufacturers to meet continuing reporting obligations even after products are placed on the market.
Reporting obligations under the California Safe Cosmetics Act and the Cosmetic Fragrance and Flavour Ingredient Right to Know Act require manufacturers to assess newly marketed and reformulated products and continue monitoring regulatory updates as ingredient lists evolve.
Compliance becomes an ongoing process rather than a one-time exercise.
Transparency Is Part of Cosmetic Compliance
In California, compliance is not determined by the formulation alone.
Proposition 65 is perhaps the best-known example. Unlike ingredient restrictions, it does not automatically prohibit the use of listed chemicals. Instead, it requires manufacturers to assess whether consumer exposure exceeds established thresholds and, where necessary, communicate that exposure through a warning label.
A proposition 65 warning is easy to misinterpret. It does not necessarily mean a product in unsafe. Instead, it reflects California’s belief that consumers should be informed when exposure to certain substances exceeds established thresholds.
California Is Setting the Direction for U.S. Cosmetic Compliance
Viewed individually, these requirements can seem like separate pieces of legislation. Together, they point in the same direction.
These requirements reveal a comprehensive approach to cosmetic compliance; one that stretch beyond the formulation to reporting, consumer transparency and post-market responsibilities.
California is increasingly setting the direction of cosmetic compliance in the United States. Manufacturers that prepare for California today are likely to find themselves better prepared for where the wider U.S. regulatory landscape is heading.
From MoCRA compliance and California reporting obligations to label reviews and Proposition 65 assessments, Obelis helps manufacturers understand how these requirements apply to their products before they become market access challenges.
Do you think California is setting the direction for cosmetic compliance across the United States, or will other states follow a different path? We’d be interested to hear your perspective.
References
State of California Office of Environmental Health Hazard Assessment. (2026). About Proposition 65. Retrieved on 14/07/2026.
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