California’s Toxic Free Cosmetic Act – A First Domino?

It’s concerning that legislation governing personal care products has seen relatively little modernization in over 80 years. This becomes even more important when you consider that the highest users of these products are often women, including during pregnancy. As research continues to demonstrate that ingredients applied to the skin can be systemically absorbed into the body, understanding what’s actually in the products we use is no longer optional—it’s essential.^1-3

The good news is that consumers are becoming more aware of the products they use, and legislative change is beginning to follow—though largely limited to places like California and parts of Europe. The question is whether California’s recent law will act as a domino, increasing awareness and driving similar changes elsewhere. That remains to be seen, but it is a step in the right direction.

There are a significant number of ingredients still commonly used in personal care products and cosmetics that raise safety concerns. In the United States, the FDA does not require premarket approval for most cosmetic ingredients and has historically had more limited authority than many consumers realize.^4-5 As a result, regulatory action has often lagged behind emerging safety concerns. California’s recent legislation represents one of the first meaningful steps within the U.S. to begin addressing this gap.

California passed the Toxic-Free Cosmetics Act, marking a notable shift in how cosmetic ingredients are regulated in the United States. Beginning January 1, 2025, the law prohibits the manufacture, sale, delivery, holding, or offering for sale of cosmetic products that contain certain intentionally added ingredients identified in the statute.⁴

These include substances such as dibutyl phthalate, diethylhexyl phthalate, formaldehyde and certain formaldehyde-releasing ingredients, mercury, specific parabens, certain aromatic amines, and several per- and polyfluoroalkyl substances (PFAS).⁴

Many of the ingredients addressed in the bill are already restricted or prohibited in the European Union, which highlights how much further other regulatory systems have gone in this area. While this law is a meaningful step forward, it still took effect years after being signed. Even so, it may serve as an important first domino toward broader reform.

While California’s move to ban 24 chemicals is meaningful, it is still only a starting point. The European Union has taken a far broader precautionary approach to ingredient safety in cosmetics.⁶

It is difficult to ignore the fact that, even today, manufacturers are not always required to fully disclose every component of their formulations in a way that is meaningful to the average consumer. This is especially concerning for products like lipstick and lip balm, where regular incidental ingestion is not just possible, but expected.

I’m generally not one to advocate for more regulation just for the sake of it. But when it comes to safety and transparency, there should be a baseline standard. Just as food products are required to disclose their ingredients, products that come into direct contact with the body should be held to a similar level of transparency.

As highlighted in the legislation, these changes also matter for salon workers—an often overlooked group with repeated, long-term exposure to cosmetic products. That is a meaningful step forward. Many workers handle and inhale these products for hours each day, and existing occupational health literature has raised concerns about repeated chemical exposure in salon environments.^7-8

That said, the delayed implementation raises fair questions. A multi-year gap between identifying certain ingredients as hazardous and removing them from the market leaves consumers and workers exposed in the meantime. Phased timelines are often justified as necessary for reformulation, inventory management, and supply chain adjustment, but the practical result is still the same: slower protection.

But realistically, why the long timeline? One likely reason is to give manufacturers time to reformulate. Many products rely on well-established, standardized formulations that include these ingredients, and reformulating them is not always simple. Maintaining product stability, texture, shelf life, and performance while removing problematic ingredients can be a genuine formulation challenge.

That said, there is a meaningful difference between reformulating with safer alternatives and simply replacing one questionable ingredient with another to achieve the same result. Developing products that avoid these concerns altogether, while still performing well, requires significantly more effort, more testing, and more intention.

There is also the practical issue of existing inventory. Products already manufactured and sitting on shelves represent a real financial investment. A phased implementation gives companies time to clear inventory and adjust formulas. Whatever explanation is given, though, the end result is the same—these products remain in circulation for longer before the changes fully take effect.

There is some good news, though, and that is that consumers are becoming more vocal about what they expect from the products they use, and some brands are starting to respond.

Even without this bill, brand self-regulation and ingredient reputation already play a significant role in determining what ingredients do and don’t get used. If consumers stop buying products made with certain ingredients, those ingredients begin to disappear from the market.

The challenge, however, is that consumers first need to know what is actually in a product—and then be able to interpret it. Ingredient labeling is not always straightforward. A single compound may appear under multiple names, and some terms are intentionally broad or simplified, making it difficult to fully understand what you are really using.⁹

Here at Nature’s Complement, we take a simple approach. We do not include ingredients that raise safety concerns, we use clean and controlled production practices, and we make our products with freshness in mind. Where possible, we rely on methods like refrigeration to help protect more delicate ingredients rather than defaulting to heavier preservative systems.

This approach does not always align with large-scale manufacturing models—but large-scale efficiency and long shelf life are not always aligned with ingredient simplicity or transparency.

So what can individuals do to better protect themselves and help drive change?

Change buying habits by:

1. Read the ingredient label every time.
2. Avoid products that make ingredient information difficult to access or require you to search elsewhere to find it.
3. Do not purchase products with ingredients you cannot identify or reasonably understand.
4. Be cautious of vague terms like “fragrance,” “parfum,” or “perfume,” which may represent complex mixtures of undisclosed components.⁹
5. Do not rely on brand recognition alone—verify what is actually in the product.
6. Share this information with family and friends. Consumer awareness is what drives change.
7. Encourage workplaces, clinics, and offices to use simplified formulations when possible. For example, WHO-recommended handrub formulations do not require added fragrance or unnecessary extras.¹⁰
8. Most importantly, remember that a brand is just a label. What matters is whether the company consistently demonstrates transparency and accountability in its formulations.

For health,

Rob

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