Hidden harm? Trade secret designations and transparency in consumer product labeling

Abstract

This study examined ingredient disclosure and concealment patterns in cosmetic products reported under California’s Safe Cosmetics Program (CSCP), with particular attention to trade secret designations and their implications for public health transparency. Drawing on a dataset from CSCP filings, descriptive analyses and logistic regressions were calculated to identify category predictors of ingredient non-disclosure, including product type, manufacturer characteristics, and chemical hazard profiles. Limitations in standard statistical models, such as rare outcomes and complete separation, required a pivot to stratified descriptive summaries and sensitivity checks. The study also documented inconsistencies in ingredient naming conventions and reporting formats that hinder public access and regulatory oversight. The results highlight the need for stronger disclosure standards, improved data coordination, and stronger labeling enforcement to enable meaningful assessment of chemical risks in personal care products. The analysis provides a framework for translating legal disclosure mandates into empirical research and policy evaluation.