§608 Safety Substantiation

Each marketed cosmetic must have data showing it is safe for users when used as directed or under customary conditions.

Key obligations

  • Maintain ingredient dossiers with toxicology summaries, exposure calculations, and supporting studies.
  • Document the tests run on finished products, such as preservative efficacy, stability, and micro.
  • Track how supplier updates or new scientific findings trigger label or formulation changes.
  • Store substantiation evidence in systems that can be shared quickly during inspections.

Evidence regulators expect to see

  • Supplier attestations, specifications, and safety certificates.
  • Laboratory reports covering micro limits, stability, and challenge studies.
  • Risk assessments linking product categories to testing plans.
  • Change-control log tying safety data updates to artwork or SOP revisions.

Intake sections that populate this section

Relevant SOP templates

Risk of non-compliance

  • FDA can deem a product adulterated and request a recall.
  • Civil lawsuits from consumers who suffer reactions without proof of safety work.
  • Retailer quality teams may pause shipments until evidence is supplied.

Further reading

Use these notes to brief leadership and justify remediation work. As you complete the intake, the Generate Package step merges your answers into each SOP so you can demonstrate compliance with §608 Safety Substantiation.