California Cosmetic Regulations Updated

Two bills concerning cosmetic manufacturing in California have been working their way through the legislative process. California Governor Jerry Brown just signed AB 2775 on Sept 14th, and SB 1249 went to the Governor on September 12th. What does it mean for handcrafted cosmetics?

AB 2775 – Professional Cosmetic Labeling

California AB-2775 requires that all cosmetics that are “for professional use only” have the ingredient declaration on them, just like all other cosmetics.

The current federal regulations for cosmetic labeling apply only to products that are intended for “household” use (which means they are purchased by a consumer and are used up).  Professional products, since they aren’t sold to the end user for use in the home, don’t have the same requirements. Except, now, in California they do.

According to the newly passed bill, Section 110371 is added to the CA Health and Safety Code. This new section requires that all professional-use products meet the same labeling requirements as consumer-use cosmetic products.

The law goes into effect on July 1, 2020. Violation of the law is a crime. There are no exemptions for small cosmetic manufacturers.


If you make cosmetics for “professional use only” AND those products are sold in California AND you don’t have the ingredients declared on the label,  you will need to update your labels to include complete ingredient declaration before July 1, 2020.

A little legal note

The current federal regulations for cosmetic product labeling say that no state can establish any cosemtic labeling requirements that are different from, or in addition to, the federal laws. So, there’s a possibility that a lawsuit or other legal action will hold off implementation of the law.

SB 1259 – Animal Testing

California SB 1259, which is likely to be signed in to law any day, prohibits any cosmetic manufacturer from selling (in California) any cosmetic that was developed or manufactured using an animal test that was conducted or contracted by the manufacturer or any supplier of the manufacturer. It will not apply to any cosmetic or ingredient that was sold in California BEFORE January 1, 2020.

The law will go into effect on July 1, 2020 and is punishable by an initial fine of $5,000 and additional fine of $1,000 each day the violation continues. It can be enforced at the state, county, or city level.


If you develop any new cosmetic that will be sold in California, make sure that all the ingredients you choose either haven’t been tested on animals or any animal testing was done prior to January 1, 2020. It is likely that the only ingredients that may be of issue are NEW ingredients developed after the cutoff date.

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15 responses to “California Cosmetic Regulations Updated”

  1. silke

    Hi Marie,
    im wondering as a small sole proprietor that wants to sell soap (homemade) do I need to list all ingredients or do I not have to list them in california? im a little confused😔

    1. Marie Gale

      The California regulations don’t change the federal requirements. IF the soap is a cosmetic, then all the ingredients must be listed on the label. Check out this post: Ingredient Declarations for Soap (US Only).

  2. Jayashree Joshi

    HI Marie, I wish to sell my homemade soaps and body butters in California. I just read your permits section. But still not clear what kind of permits I need. The post says sales tax which means just a business permit? Is it possible to provide more details? I tried pouring over CA.gov but founds nothing that describes my category of soapmaking. Tried contacting the helpdesk too but nothing!!! Feeling frustrated. They actually directed me towards a private attorney!!

    1. Marie Gale

      California doesn’t have specific registration requirements for businesses making soap or cosmetics. What is needed in California are just the regular things you would need for any business. If you want to set up an LLC or partnership, then you need to register that with the STATE. If you are a sole proprietorship and want to get a “doing business as” name, you do that with the COUNTY. You will need to register with the STATE for sales tax collection (which means you’ll need a federal tax ID number from the IRS).

      You MAY have zoning requirements for the location of your business. Those are COUNTY or CITY requirements. In some cities or counties there are zoning restrictions on having certain types or sizes of businesses in residential areas and some have requirements for where “manufacturing” businesses can be located. That’s what’s usually called a “business permit.”

      1. Jayashree Joshi

        Thank you so much Marie

      2. Josephina

        Thank you for this info. I couldn’t find anything on California laws, and boom, here it is!

  3. Breena Shelby

    I want to start a soap business and I want to take every precaution. Where should I go to actually have my cosmetic soaps checked for safety/ toxicology tests?

    1. Marie Gale

      I’m sorry, but I don’t have any recommendations for safety/toxology tests. If you are making actual soap, without significant chemical additives, you probably don’t need outside testing.

    2. I want to re sell soap (organic handmade) what are the legal follows? TIA

      1. Marie Gale

        It depends on how you are reselling. If you are buying packaged soap wholesale and then selling it (like a store does), then you don’t have any specific cosmetic requirements.

        If you are purchasing soap and then packaging it (or having it packaged for you) and you are the “responsible party” (your name is on the package), then it depends on how you receive the soap and what you say about it.

        If you are selling your product “for professional use,” then you have to make sure your product follows the same labeling as for consumer products.

  4. Josmary Flores

    Where can I find information about if I’m allowed to run a soap business from home. I looked everywhere on Google but nothing comes up

    1. Marie Gale

      If you are in California, I don’t think there are any statewide regulations that require any registration or licensing for making soap. However, you should check locally (city or county) for any limitations on home-based businesses in general, and in particular “manufacturing” in the home. Some counties and cities have regulations about what can be done in residentially-zoned areas. You will also have some regular business requirements at the state level; those apply to any business (taxes, reporting, things like that).

  5. Indi

    Thanks a lot!

  6. Debbie

    Thank you

  7. Danielle Levenson

    Thank you Marie for keeping us up to date on changes to the laws concerning cosmetics!

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