Consumer Commitment Code

PCPC member companies have a long history of science and safety best practices, often going beyond what is required by law. PCPC instituted a Consumer Commitment Code in 2006 to strengthen practices already in place for many companies and to incorporate new practices, such as a Safety Information Summary Program, which made cosmetics product and ingredient safety information readily available to the U.S. Food & Drug Administration (FDA). The Modernization of Cosmetics Regulation Act (MoCRA) of 2022 makes most of the Code’s voluntary provisions mandatory, thus precluding the need for a voluntary Code (appendices).  

The following principles constitute PCPC’s Consumer Commitment Code:

  1. A company should market cosmetics products only after ensuring every ingredient and finished product has been substantiated for safety. The decision that an ingredient has been substantiated for safety may be based on a finding by the Expert Panel for Cosmetic Ingredient Safety’s Cosmetic Ingredient Review (CIR) that such ingredient is safe for the intended use or on other appropriate data and information.
  2. When marketing a cosmetics product containing an ingredient that exceeds the concentration or applications reviewed by the Expert Panel, or for which the Expert Panel has found the “Use Not Supported by the Data and Information Submitted to the CIR,” a company should possess information sufficient to substantiate the safety of the ingredient as used in such product and be willing to make that information available for inspection by the FDA.
  3. When marketing a cosmetic product, the presence of any of the 26 internationally recognized contact allergens listed in Table 1 shall be disclosed when its concentration is greater than 0.001% in leave-on cosmetic products or 0.01% in rinse-off cosmetic products. Disclosure using their INCI name can be provided on labels or in labeling, including written, printed or graphic materials or by other electronic means generally available to the public.1
  4. A company should participate in the applicable parts of the FDA Voluntary Cosmetic Reporting Program (VCRP) set forth in 21 CFR Parts 710 and 720 for products marketed in the United States, and file timely reports regarding its manufacturing establishments and ingredient usage.
  5. Although serious and unexpected adverse events are extremely rare for cosmetics products, a company should notify the FDA of any known serious and unexpected adverse event as a result of the use of any of its cosmetics products marketed and used in the United States.
  6. A company should maintain a safety information summary of ingredient and product safety information and data regarding its cosmetics products marketed in the United States as specified in PCPC’s Safety Information Summary Program Guideline, and make any information in that safety information summary available for inspection by FDA under the conditions specified in that program.

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The Code is voluntary and should not be construed as a legal standard. All companies have an independent obligation to ascertain their cosmetics products comply with all current laws and regulations.


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1 This provision is added to the Consumer Commitment Code as of February 2021. Companies adhering to the Code will have a reasonable amount of time to comply with this provision.