The bill amends the Federal Food, Drug, and Cosmetic Act to require brand owners to disclose complete ingredient lists for cosmetics, explicitly including fragrance and flavor components, and to make those lists machine‑readable and publicly accessible on their websites. It also requires packaging to show full ingredient lists and a prescribed consumer-facing statement (with a URL) when any ingredient appears on a consolidated hazardous-ingredient master list that the FDA must create and maintain.
This is a structural transparency law: it forces cosmetic supply chains to push detailed composition data into public and vendor-facing channels, establishes a single FDA master list compiled from dozens of federal, state, and international hazard lists, and ties noncompliance to existing misbranding/adulteration authorities. If enacted, the bill will change labeling, e‑commerce data flows, and trade‑secret practices while creating new operational and regulatory burdens for brand owners and suppliers.
At a Glance
What It Does
The bill requires brand owners to publish a machine‑readable, full ingredient list (including each fragrance and flavor component and its functional purpose) on their websites and provide that data to internet vendors. It directs FDA to establish and maintain a consolidated master list of hazardous chemicals drawn from specified U.S. and international lists and requires packaging labels to carry a URL statement when any master-list chemical is present.
Who It Affects
The rule applies to any entity defined as a brand owner that sells cosmetics in interstate commerce, manufacturers and suppliers of fragrance and flavor mixes, professional-use product sellers (salons, spas), and internet vendors who list or sell cosmetics. Regulators will also inherit a new public master list and notification duties.
Why It Matters
It converts many previously confidential or aggregated ingredient disclosures into structured public data, enabling consumer-facing warnings, retailer filters, and downstream compliance checks. The FDA master list centralizes hazard references and creates a formal trigger for labeling obligations — a governance shift for how chemical hazards in cosmetics are identified and disclosed.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The bill inserts a new subchapter into the FD&C Act that treats failure to disclose fragrance and flavor ingredients as grounds for misbranding or adulteration and creates specific website- and label-based disclosure duties for brand owners. On the website side, brand owners must publish a complete ingredient list in a format that automated systems can read, not lock behind registration walls or CAPTCHAs, and conform to current web accessibility guidelines.
The disclosure must include each fragrance and flavor component in descending order, indicate the functional purpose of each fragrance or flavor ingredient, link to any applicable lists on which an ingredient appears, and provide access to safety data sheets for products intended for professional use.
For packaging and labeling, the bill requires that labels list every ingredient in descending order as well; if any ingredient appears on the FDA master hazardous list, the label must include a fixed consumer-facing sentence directing users to the brand owner’s website URL for health-impact information. The law phases in obligations (shorter for web disclosures, longer for labeling) and ties the timing for brand-owner updates to changes in the authoritative lists that feed the FDA master list.The FDA must assemble a master list within six months that consolidates chemicals from a long set of U.S., state, and international hazard databases and make that list publicly available and push updates to a voluntary subscriber list.
The agency must post semiannual summaries of changes and notify subscribers of each update. Brand owners then have a limited period after an authoritative-list update to revise their website disclosures so the consumer-facing data stays in sync with evolving hazard determinations.The bill also refines definitions that will matter in implementation: it expands the statute’s coverage to include products intended for consumer or professional sale, defines what counts as an ingredient (including breakdown products and components of mixtures), and defines “electronically readable” to require machine readability and broad access.
Several definitions are left to agency rulemaking (for example, which establishments qualify as professional-use settings), so many practical questions will be resolved in implementing regulations.
The Five Things You Need to Know
Brand owners must publish a full, machine‑readable ingredient list for each cosmetic on their website, including each fragrance and flavor component and the functional purpose of each fragrance or flavor ingredient.
If any ingredient in a product appears on the FDA’s consolidated master hazardous-ingredient list, the product label must include the statement: 'For health impacts related to any ingredients in this product, visit: www.llll.' with the brand owner’s URL filled in.
The FDA must create a master list within 6 months that consolidates the specified U.S.
state, and international hazard lists, post it publicly, maintain it, and notify subscribers of updates within 30 days.
When an authoritative list is updated, brand owners must revise their online disclosures to reflect that update not later than 7 months after formal notice by the authoritative body; FDA must publish semiannual summaries of master-list changes.
The bill requires website disclosures to be machine‑readable, searchable by crawlers, accessible under current WCAG standards, and not gated by registration, CAPTCHAs, or other access tests—expanding how brands must publish ingredient data to meet accessibility and vendor-use needs.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Expands the cosmetic definition to include professional-use products
This change explicitly brings products sold for professional application within the statutory definition of a cosmetic. Practically, the scope expands regulatory coverage so the bill’s disclosure rules apply not only to retail consumer items but also to products sold to salons, spas, and other professional settings once those settings match the Secretary’s regulatory definition.
Requires machine‑readable full ingredient lists and SDS links
Section 615 directs brand owners to publish each cosmetic’s complete ingredient inventory—including fragrance and flavor components—in electronically readable format on their own websites and make that data available to relevant internet vendors. It also requires that professional-use products include a link to the safety data sheet. The provision emphasizes automated accessibility and vendor interoperability rather than a specific data standard, leaving technical formatting choices to be shaped by implementation.
Labeling must include full ingredient lists and a hazard‑trigger statement
Effective later than the website rule, packaging must state every ingredient in descending order. If any ingredient appears on the FDA master hazardous list, the label must insert a short, standardized consumer-facing statement directing people to the brand owner’s web page for health-impact details. This creates a two-tier disclosure system: immediate online detail and an on-package pointer when a master-list chemical is present.
Defines which chemicals trigger label statements and requires an FDA master list
The bill enumerates numerous categories and named lists—EPA IRIS neurotoxicity and carcinogen classifications, TRI PBT entries, CDC exposure reports, CERCLA hazardous substances, NTP reproductive toxicants, EU REACH candidate lists, IARC groups, and various state regulations among them—that feed the master list. FDA must compile those sources into a single publicly posted master list within six months, maintain it, provide a voluntary distribution list for updates, and publish semiannual summaries of changes. The practical effect is to make hazard determinations from many systems operational as label triggers under U.S. law.
Preserves state authority to regulate ingredients and transparency
The bill modifies the statutory limitations to explicitly allow states (and political subdivisions) to prohibit or limit ingredients, maintain existing reporting obligations, and adopt or continue laws that provide greater transparency than this Act’s baseline. It also clarifies that the Modernization of Cosmetics Regulation Act of 2022 does not broadly preempt state measures except where that law expressly does—leaving room for overlapping state requirements and local programs.
Operational definitions and accessibility requirements
Section 617 sets operational definitions for 'brand owner,' 'electronically readable format,' 'ingredient,' 'fragrance ingredient,' 'flavor ingredient,' and 'professional use.' Notably, 'electronically readable' is tied to machine readability, search-engine accessibility, and adherence to Web Content Accessibility Guidelines. The statute therefore imposes both substantive disclosure duties and technical accessibility constraints that will shape how brands publish data.
This bill is one of many.
Codify tracks hundreds of bills on Healthcare across all five countries.
Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers with chemical sensitivities or allergies — They gain direct access to full ingredient breakdowns (including fragrance and flavor components) and easier ways to check whether products contain chemicals identified as hazardous across multiple authoritative lists.
- Dermatologists, allergists, and clinicians — Structured, machine‑readable ingredient data and label pointers make it easier to match product contents to patient reactions and to document exposures for clinical decision‑making.
- Retailers and online marketplaces — They can use standardized, vendor‑facing ingredient feeds to power search filters, age/health warnings, and compliance checks, reducing friction for product listing and enabling automated risk‑based merchandising.
- Public-interest researchers and NGOs — The FDA master list and public ingredient disclosures provide a richer dataset for epidemiologic studies, product surveillance, and targeted advocacy.
- Workplaces and professional service providers (salons/spas) — Mandatory SDS links and clearer ingredient inventories improve occupational health information for employees and clients.
Who Bears the Cost
- Brand owners and manufacturers — They must inventory and disclose full ingredient breakdowns (including often‑protected fragrance/fragrance-component formulas), update web and label content to remain synchronized with master-list changes, and absorb technical and accessibility implementation costs.
- Fragrance and flavor suppliers — The requirement to disclose individual components exposes formulations many suppliers treat as trade secrets, creating commercial risk or pressuring reformulation and contractual renegotiation.
- Small and indie cosmetics companies — Limited legal, regulatory, and IT resources mean higher per‑unit compliance costs for producing machine‑readable data, maintaining updates, and redesigning packaging to accommodate full ingredient lists and the required label statement.
- The Food and Drug Administration — The agency must assemble, publish, maintain, and notify stakeholders about a consolidated master list and manage a subscription distribution list and update summaries, adding administrative work without explicit funding in the bill.
- Internet vendors and marketplaces — They will need to ingest, store, and display standardized ingredient data and ensure linkage between product listings and brand-owner web disclosures, creating integration and verification costs.
Key Issues
The Core Tension
The central tension is between the public’s right to know about chemical hazards in consumer and professional cosmetics and the commercial need to protect proprietary fragrance and flavor formulations and to manage compliance costs; the bill increases transparency and consumer protection but does so by imposing technical, operational, and potential commercial burdens that will shift supply‑chain practices and invite regulatory dispute over implementation details.
The bill forces a trade‑off between transparency and trade‑secret protection. By treating fragrance and flavor components as ingredients that must be disclosed online and linked from labels when hazardous, the statute creates pressure on suppliers to reveal proprietary formulations or to reformulate.
The text requires machine‑readable, accessible disclosures but leaves format standards and enforcement details to the FDA, creating short‑term uncertainty about how companies should structure feeds, what metadata to provide, and how to handle mixtures and proprietary blends.
Operational timing and update mechanics create implementation risks. FDA must compile a master list from a long and diverse set of national, state, and international sources within six months, and brand owners must reconcile their product inventories with those lists under a seven‑month update window tied to 'authoritative body' notices.
That chain creates potential synchronization gaps and a surge of consumer-facing changes following foreign regulatory actions or international candidate list additions. The bill ties noncompliance into existing misbranding/adulteration sections but does not specify new penalties, leaving ambiguity about enforcement priorities and remedies.
Finally, definitions such as 'professional use' and the agency’s authority to treat components as 'ingredients' for disclosure are likely to be the subject of contested rulemaking and private‑sector litigation.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.