CARB 2026: California's Perfume and Cosmetics Regulatory Requirements – What to Do by March

The California Air Resources Board (CARB) has initiated the “2025 Personal Fragrance Products Technical Assessment” a data collection program covering companies that marketed perfumes, body sprays deodorants, aftershaves, and other products in which fragrance in included up to 20%, in California, during 2025.

This initiative is not a simple survey, but a real regulatory fulfillment required by the Consumer Products Regulation, aimed at assessing whether the sector will be able to comply, in the coming years, with the new limits on volatile organic compound (VOC) emissions, in force from 2031.

All companies listed as a “Responsible Party” on the label—that is, manufacturers, importers, or distributors who sold or offered these products in California in 2025—are required to participate. Data submission is mandatory for these entities.

A comprehensive report must be submitted to CARB by March 31, 2026, using the official reporting tool provided by the authority. The report includes, among other things, company information, a list of affected products, sales data, composition and formulation, labels, formulator references, and a disclaimer of responsibility for the accuracy of the data. Additionally, a written document describing the research and development activities undertaken to reduce VOCs and prepare for future regulatory requirements is required.

If the formulations are created by third parties, CARB will contact the formulators directly to gather technical information, but it remains the company's responsibility to correctly identify the parties involved.

This requirement is required by a mandatory regulation and is not optional. Failure to submit the report, submitting incomplete data, or providing incorrect information may trigger enforcement proceedings by CARB. Under the general regulatory framework, violations of reporting requirements can result in significant administrative penalties, including fines that, in the most serious cases, can be assessed on a daily basis. Beyond the financial aspect, non-compliance can expose the company to more frequent inspections and future difficulties in accessing the California market.

For companies in the cosmetics and fragrances sector, this reporting therefore represents a strategic step, not only to comply with current obligations but also to demonstrate reliability and preparedness with respect to ongoing regulatory developments.

It is essential to begin data collection early, verify which products are included in the assessment scope, coordinate with formulators, and prepare complete and consistent documentation, avoiding delays or errors that could have significant consequences.

For expert support in verifying compliance, preparing reporting, and managing relationships with CARB, contact Cosmetic Solution Srl, which offers an advanced team of professionals specializing in regulatory compliance for the cosmetics and chemical sectors.

We remain available to assist you throughout the entire process.