The rule count is the full rule base exactly as our database stores it, including 61 rules that fire only in EU mode — an opt-in scan setting adding 3 screening categories under EU Regulation (EC) No 1223/2009 (fragrance-allergen disclosure and Annex II/III restrictions). The requirement count is United States coverage only: obligations that can arise only in EU mode are excluded.
Rule: One named check in our rule base, counted exactly as the database stores it: every federal, state, and retailer rule, every claim pattern, every ingredient-hazard entry, and every Proposition 65 listed chemical is one rule. A single statute can contribute many rules, one per substance name it reaches, so this figure is larger than the requirement count by design.
Requirement: One obligation a label can independently fail, counted the way its own source document enumerates it: a CFR section, a state statute, one line of a retailer's published policy, one claim pattern, one ingredient-hazard category, or the Proposition 65 warning duty.
The two figures count one rule base at two grains: the Proposition 65 screen alone is 903 rules under a single warning requirement, and the ingredient-hazard table is one rule per substance name across 12 hazard categories. Every scan additionally evaluates a fixed catalog of federal, state, claims, and OTC-boundary rules (the "rules evaluated" figure on your scan results); ingredient-hazard screening and retailer program checks run on top of that catalog. The regimes covered are listed below, with the statute behind each.
How to read this table. 15 of the 20 states ban a chemical class — one encoded rule reaches every member of that chemical family in your ingredient declaration; the rest enumerate substances, screened by name.
| Code | State | Governing law | What we screen |
|---|---|---|---|
| AR | Arkansas NAMED | Hair relaxer carcinogen and reproductive-toxicant warning labels (Act 964 of 2025; Ark. Code Ann. §20-56-224), in force since 2025 | 1 state rule · screened by name |
| CA | California PFAS CLASS | Prop 65 (H&SC §25249.6), Safe Cosmetics Program (SB 484), Toxic-Free Cosmetics Act sale ban (AB 2762, §108980), PFAS ban (AB 2771, §108981.5) | 9 state rules · including a whole-class PFAS matcher |
| CO | Colorado PFAS CLASS | PFAS prohibition (HB 22-1345; C.R.S. §§25-15-601 to -604); hair relaxer carcinogen warning labels (Hair Product Transparency and Safety Act, HB 26-1135; C.R.S. §25-5-429, duty on and after Jul 1, 2027) | 2 state rules · including a whole-class PFAS matcher |
| CT | Connecticut PFAS CLASS | PFAS label-and-notify (Conn. Gen. Stat. 22a-903c; Public Act 24-59; full ban Jan 1, 2028) | 1 state rule · including a whole-class PFAS matcher |
| HI | Hawaii NAMED | Reef-Safe Sunscreen, oxybenzone/octinoxate (Act 104; HRS §342D-21) | 1 state rule · screened by name |
| IL | Illinois PFAS CLASS | Chemicals in Cosmetic Products Act (P.A. 104-0545, 410 ILCS 612; eff. Jul 1, 2028), PFAS Reduction Act cosmetics ban (P.A. 104-0231, 415 ILCS 170/45; eff. Jan 1, 2032), and mercury prohibition, in force since 2009 (Mercury-added Product Prohibition Act, 410 ILCS 46/22) | 3 state rules · including a whole-class PFAS matcher |
| LA | Louisiana NAMED | Mercury limit 10 ppm in formulated products incl. cosmetics (La. R.S. 30:2576; 30:2573(A)(2); Mercury Risk Reduction Act) | 1 state rule · screened by name |
| ME | Maine PFAS CLASS | PFAS in Products Act (LD 1537; 38 MRS §1614) | 1 state rule · including a whole-class PFAS matcher |
| MD | Maryland PFAS CLASS | PFAS ban (HB 643; Md. Health-General §21-259.2) | 2 state rules · including a whole-class PFAS matcher |
| MN | Minnesota PFAS CLASS | PFAS ban, Amara's Law (Minn. Stat. §116.943); mercury prohibition (§116.92 subd. 8i); children's-product formaldehyde ban (§325F.177) | 4 state rules · including a whole-class PFAS matcher |
| NH | New Hampshire PFAS CLASS | PFAS-added product ban, cosmetics (RSA 149-M:64, IV(b); PFAS per 40 C.F.R. 705.3; on and after Jan 1, 2027) | 1 state rule · including a whole-class PFAS matcher |
| NJ | New Jersey PFAS CLASS | PFAS class ban (N.J.S.A. 56:3-53 et seq.; P.L. 2025 c. 202; eff. Jan 12, 2028) | 1 state rule · including a whole-class PFAS matcher |
| NM | New Mexico PFAS CLASS | PFAS Protection Act — cosmetics sale ban (HB 212 §3(C)(3), 2025 N.M. Laws ch. 102; eff. Jan 1, 2028) and on-product PFAS mark (20.13.2.13 NMAC; eff. Jan 1, 2027) | 1 state rule · including a whole-class PFAS matcher |
| NY | New York NAMED | PFAS ban + Mercury restriction (Environmental Conservation Law §37-0117 / §37-0117(8)) | 3 state rules · screened by name |
| OR | Oregon PFAS CLASS | SB 546 cosmetics sale ban (Or. Laws ch. 575, §4; eff. Jan 1, 2027) | 4 state rules · including a whole-class PFAS matcher |
| RI | Rhode Island PFAS CLASS | PFAS class ban in covered products incl. cosmetics (Consumer PFAS Ban Act of 2024; R.I. Gen. Laws 23-18.18-4(a); 23-18.18-3; eff. Jan 1, 2027) | 1 state rule · including a whole-class PFAS matcher |
| VT | Vermont PFAS CLASS | PFAS ban (Act 131 / S.25; 9 V.S.A. §2494b) | 5 state rules · including a whole-class PFAS matcher |
| VA | Virginia PFAS CLASS | Humane and Toxin-Free Cosmetics Act sale ban — 11 named substances and 13 enumerated PFAS (HB 122; Va. Code §59.1-574.2; eff. Jul 1, 2026) | 2 state rules · including a whole-class PFAS matcher |
| WA | Washington PFAS CLASS | Toxic-Free Cosmetics Act (RCW 70A.560, HB 1047), phthalates, PFAS, formaldehyde releasers (WAC 173-339) | 5 state rules · including a whole-class PFAS matcher |
| WI | Wisconsin NAMED | Mercury prohibition in cosmetics, toiletries and fragrance products (Wis. Stat. 299.49(2)(f)5; 2009 Wis. Act 44) | 1 state rule · screened by name |
In the remaining 30 states, federal FDA 21 CFR labeling requirements still apply and are checked on every scan. State coverage expands as legislatures act, and we add jurisdictions on request. Request a state →
| Regime | What we screen |
|---|---|
| MoCRA labeling 21 U.S.C. § 364c, § 364e |
The domestic adverse-event contact (checked on every scan as a blocking error), the professional-use statement, and a foreign-facility registration advisory that never fails a scan on its own. Most of MoCRA is not a labeling law: facility registration, product listing, safety substantiation, good manufacturing practice and adverse-event recordkeeping live in your filings and formulation file, where no label reader can see them — each is covered in Where Our Scope Ends with the route to satisfy it. |
| Retailer Program | What we check |
|---|---|
| Amazon Beauty | Screened against the program’s published banned-ingredient list and labeling requirements |
| Sephora | Screened against the program’s published banned-ingredient list and labeling requirements |
| Target | Screened against the program’s published banned-ingredient list and labeling requirements |
| Ulta Conscious Beauty | Screened against the program’s published banned-ingredient list and labeling requirements |
| Walmart | Screened against the program’s published banned-ingredient list and labeling requirements |
| Whole Foods Market Body Care | Screened against the program’s published banned-ingredient list and labeling requirements |
The warning is often present but wrong — pre-2018 wording, or missing the required chemical name, URL, or symbol. We screen the warning's presence, its regulated format, and the entire OEHHA list: 903 listed chemicals (983 raw OEHHA listings, deduplicated; retrieved 2026-08-04), matched under the names a label actually prints, with 13 of the most cosmetically relevant also carried in the ingredient-hazard layer at violation severity. A listed-chemical match raises an advisory, never a violation, so a clean label produces none; qualified listings ("Talc containing asbestiform fibers", "Retinol/retinyl esters… in excess of 10,000 IU") are screened as written, so plain talc or retinol is not flagged on that basis alone. Sourced against Health & Safety Code §25249.6 and 27 CCR §25600 et seq.
Ingredient-name validation uses the European Commission's CosIng cosmetic ingredient database (ec.europa.eu/growth/tools-databases/cosing) to recognise official INCI names. © European Union, 1995–2026. Reused under Commission Decision 2011/833/EU; the European Commission does not endorse CPGShield or this use of its data. The California Proposition 65 list is published by OEHHA, and the Code of Federal Regulations is a US government edict; neither carries copyright.
Every ingredient-hazard entry is sourced from an official regulatory list (OEHHA, eCFR, state statutes and administrative codes, EUR-Lex). A line-by-line citation audit against primary sources is in progress; entries awaiting confirmation are flagged unverified in the product, with per-entry status visible in the Rule Library → Ingredient Hazards tab. Independent review by outside regulatory counsel is a separate, planned gate and has not yet occurred. Corrections: support@cpgshield.com.
CPGShield reads what is on the label. These obligations live elsewhere — your formulation file, your FDA filings, a testing lab — where no label reader can see them. Each is listed below with the route to satisfy it:
| Obligation | Why it is out of scope · what to do |
|---|---|
| Formula safety substantiation | A toxicological judgment about ingredients and use levels, made an explicit obligation by MoCRA. → Engage a cosmetic safety assessor; your contract manufacturer may already hold a safety assessment. |
| MoCRA registration & product listing | FDA account status, not printed on the label (the responsible-person contact is checked on every scan). → File through FDA Cosmetics Direct and calendar the renewal. |
| OTC drug labeling (sunscreen, acne, antiperspirant) | A Drug Facts panel moves the product to the OTC rulebook — we detect the panel and screen sunscreen items, but do not certify format under 21 CFR 201.66. → Have an OTC specialist review the panel against the monograph. |
| Markets outside the United States | EU ingredient screening is an opt-in scan mode; full EU entry additionally needs a Product Information File, an EU Responsible Person and CPNP notification. → Turn on EU mode, then engage an EU Responsible Person service; treat each market separately. |
| Testing-dependent claims | SPF, broad-spectrum and water-resistance rest on test data we cannot see; we check the wording only. → Keep the test reports on file before the claim goes to print. |
| Country-of-origin marking | US Customs law, driven by where manufacturing occurred. → Confirm with your customs broker or importer of record. |
| Retailer terms beyond the five encoded programs | Buyer-specific vendor manuals are not published anywhere we can read. → Request the manual from each buyer; send us any published standard and we will evaluate it for encoding. |