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cleangirlshop.com

The formula belongs to whoever made it. Everything that happens after a customer clicks buy belongs to whoever sold it, and almost none of that is about what is in the bottle. A federal table of 6,402 entries has no row for cosmetics and classifies the catalog anyway. A 1975 shipping rule converts a banner promise into a legal deadline. The subscription rule everyone still cites was struck down whole in July 2025 and the statute behind it produced a billion dollar penalty ten weeks later. And the sales tax position that a marketplace is widely believed to absorb is the one thing it provably does not.
00:00:00:00 Trailer  ·  :26  ·  Looping
The argument

The formula is somebody else's problem. The shipment is yours.

Start with the table, because the table is where a beauty order stops being a beauty order. The federal hazardous materials table runs to 6,402 entries and classifies by flash point, propellant and pressure, never by what a thing is sold as; we parsed every row and not one of them says cosmetics, nail polish, hairspray or fragrance.1 The catalog is classified anyway, under three entries almost nobody would guess: nail lacquer ships as paint, alcohol fragrance as perfumery products, and anything with a propellant as aerosols.2 There is one paragraph of the regulations that names cosmetics expressly and excepts them outright, and it turns on nothing but alcohol strength and container size, which makes it the single most commercially useful provision in this entire subject.3 The most repeated claim in shipping-compliance writing, that federal transport rules forbid flammable aerosols on passenger aircraft, is simply not what the table says; column 9A reads 75 kilograms. What actually stops a storefront is the postal regulations and the carrier's own contract.4 And limited quantity, the route nearly every beauty storefront ships on, is not an exemption from the rules. It is six enumerated reliefs with the training, testing and documented records left standing, retested every three years, with no small-business carve-out anywhere in it.5

Then the promise, which is the cheapest thing on a storefront to write and the most expensive to get wrong. The federal order rule gives a seller thirty days to ship only if the seller has said nothing at all; state a time clearly and that stated time governs instead, so the banner reading two-day shipping has replaced a thirty-day default with a two-day obligation in the seller's own words.6 When the date cannot be met the seller must offer the buyer a choice, unprompted, before the deadline passes, and what silence then means flips entirely at thirty days: under it, silence is consent to the delay; over it, silence cancels the order.7 If the order is canceled the refund is due in seven working days and the rule defines what a refund is, in five forms, none of which is store credit; two federal enforcement actions turned substantially on that one substitution.8 Fifty years of cases against catalog companies, the first wave of online retailers and native direct-to-consumer brands all key on the same thing, and it is not the product. It is how specific the promise was and how often it was missed.9 The rule imposes no recordkeeping requirement at all. It imposes two rebuttable presumptions instead, which is the same thing pointed the other way, and the agency's own guide names the five records it expects to see.10

Then the billing, where most of what is currently in print is describing a rule that no longer exists. A federal appeals court vacated the click-to-cancel rule in its entirety on 8 July 2025, on a procedural failure, six days before its own compliance date, and the agency deleted the text from the regulations the following February.11 Vacating an amendment reinstates what it replaced, so the negative-option regulation actually in force today is the one written in 1973 for prenotification plans, which still speaks of mailing a form back and guaranteeing return postage, and which the agency estimates reaches twenty-five sellers nationwide.12 None of that mattered as much as the commentary assumed, because a 2010 statute already makes it unlawful to charge anyone online through a negative option feature without three specific things and deems a violation to be a rule violation in its own terms: ten weeks after the vacatur it produced the largest civil penalty ever obtained in a case of that kind.13 What is left is state and local law, where one state put the exact phrase click to cancel into its code, a second is widely assumed to have done so and did not, and a city rule under that name takes effect the day this page went up.14 And one state answers an unconsented continuing shipment not with a penalty but with a transfer of title: the goods become an unconditional gift, with no obligation on the recipient at all.15

Then collection, which is the half of this that has no federal floor whatsoever. There is no federal sales tax and no federal registration; every collection duty on this page was created by a state. The 2018 decision that ended the physical-presence rule is constantly described as setting a hundred thousand dollar standard and it set nothing of the kind, and the state whose statute it reviewed has since repealed the transaction prong the Court quoted.16 Selling through a marketplace hands over the remittance and not the position: one state forbids the seller to collect on a facilitated sale while another counts those same sales toward the $500,000 threshold that decides whether the seller must register for the orders the marketplace never touched.17 The same bottle of sunscreen, a drug to the federal regulator, is exempt in two states, taxed under a definition written to override that federal label in a group of others, and charged at more than six times the medicine rate in one.18 And three things in this picture are simply not counted: the 2022 federal classification deleted the code for selling online, the statistical agency publishes no e-commerce figure for beauty retail, and this exact phrase has no measurable search demand, reading zero in 250 of 262 weeks.19

That last number is on the page because a buyer will find it in ten minutes if it is not. The same discipline governs everything else here. This page prints no market size for clean beauty, no category growth rate, no consumer-perception percentage and no absolute search volume, because the public series that would support them do not exist. It names no retailer, brand, platform or certifier as non-compliant, deceptive or misleading. It does not tell anyone their products are unregulated, which is false. It does not say whether this name is registrable, in either direction. Twelve specific claims were refused in writing during the build, and they are published as the twentieth snapshot so a buyer can hold us to the list.20

Domain
cleangirlshop.com
Length
13 characters + .com
TLD
.com, the default
Category
Beauty and personal care retail
Hyphens or numerals
None
Federal code for selling online
Deleted in the 2022 revision
Measured demand for the exact phrase
Zero in 250 of 262 weeks
Price
$3,500 buy it now
What moves the goods
6,402

Rows, none of them cosmetics

Every row parsed. The catalog is classified by chemistry.1

70%

The alcohol ceiling that lets you out

The one paragraph that names cosmetics, and excepts them.3

75 kg

What column 9A actually allows

Transport law is not what stops the parcel. The mail is.4

3 years

Retraining under the exception

Six reliefs granted. Training, testing and records stay.5

What moves the money
2 days

What a two-day banner costs you

Say nothing and you have thirty. Say two and you have two.6

0

Sections of the rule left standing

Vacated whole, six days before its compliance date.11

$1B

Civil penalty under the statute

Ten weeks after the rule died. No rule was ever needed.13

$500,000

Threshold your marketplace sales count toward

One state forbids you to collect. Another counts them.17

Find your fit

Six businesses
that live at this address.

Pick the one closest to yours and the twenty snapshots below will mark the ones built for it. Nothing is hidden; the grid only marks and scrolls.

Twenty use cases

What a business
looks like here.

Each panel below is a working miniature of a site that could run at this address: navigation, hero, product screen and proof numbers, followed by a plain note on how that business would position the name. All twenty stay on screen at all times; a lane simply marks its own. The domain sits in the browser bar of every one of them, whole and unbroken, because the name is the thing being sold.

01

The Table Has No Entry For Cosmetics

How a beauty order becomes a regulated shipment
🔒 cleangirlshop.com
HMT6,402Shipper Search the table

Six thousand rows.
Not one of them
says cosmetics.

The federal hazardous materials table classifies by chemistry and physical behavior, never by what a thing is sold as. There is no row for cosmetics, nail polish, hairspray or fragrance. A beauty product becomes a regulated shipment because of its flash point, its propellant or its pressure, and the law puts that determination on the person shipping it.

49 C.F.R. 172.101 HAZARDOUS MATERIALS TABLE · ALL 6,402 ROWS PARSED · OCTOBER 1, 2026OUR SEARCH
Proper shipping name containing“cosmetic” or “cosmetics”0
Proper shipping name containing“nail polish”, “hairspray”, “dry shampoo”0
Proper shipping name containing“fragrance”, “toiletries”, “hair”0
Control, proving the parse worksrows returned for “Paint”6
The person shall class and describe the hazardous material in accordance with parts 172 and 173.49 C.F.R. 173.22(a)(1), VERBATIM. THE DUTY IS THE SHIPPER'S.
WHY THIS IS THE RIGHT PLACE TO START, AND NOT A TECHNICALITYEvery other page in this category starts from what is in the bottle. The transport regime does not care. It asks three questions - how low is the flash point, what is the propellant, what is the pressure - and the answers put an ordinary beauty catalog into three different hazard classes before anyone has mentioned an ingredient. The storefront, not the brand that made it, is the one the regulation calls the shipper.
NOTHING ON THIS PAGE IS ABOUT WHAT IS IN A PRODUCT. IT IS ABOUT WHAT HAPPENS TO IT AFTER SOMEONE BUYS IT.THE WHOLE PAGE
6,402rows in the table
0that name a beauty product
2026-10-01date we searched
How they position itA storefront operator learns this the first time a carrier refuses a parcel. Owning the address that explains it before that happens is worth more than any product page.
02

Nail Polish Is Paint

The three table entries an ordinary catalog actually hits
🔒 cleangirlshop.com
UN1263UN1266UN1950 See the rows

Polish is paint.
Perfume is a
flammable liquid.
Hairspray is a gas.

Three entries cover most of what a beauty storefront ships. Nail lacquer travels under the paint entry, alcohol fragrance under perfumery products, and anything with a propellant under aerosols. We print the actual table columns, because the air and ground limits live in them and nowhere else.

49 C.F.R. 172.101 · COLUMNS 2 THROUGH 9B, QUOTED FROM THE TABLE ITSELFPRIMARY SOURCE
THE THREE ENTRIESAS WRITTEN
NAIL LACQUER · UN1263, CLASS 3Proper shipping name, in full: “Paint (including paint, lacquer, enamel, stain, shellac solutions, varnish, polish, liquid filler and liquid lacquer base)”. Packing group I, II or III by flash point and boiling point, not by product. Passenger aircraft limits 1 L / 5 L / 60 L; cargo 30 L / 60 L / 220 L.
ALCOHOL FRAGRANCE · UN1266, CLASS 3“Perfumery products with flammable solvents”, packing group II or III. Passenger aircraft 15 L and 60 L; cargo 60 L and 220 L. Card 03 is the exception that takes most of this inventory back out of the regime entirely.
PROPELLANT PRODUCTS · UN1950, DIVISION 2.1 OR 2.2“Aerosols, flammable” or “Aerosols, non-flammable”, each not exceeding 1 L capacity. No packing group. The division is assigned by test, not by guess: 2.1 at 85 percent or more flammable components and 30 kJ/g or more, 2.2 at 1 percent or less and under 20 kJ/g, and anything between the two must be test-classified.
THE ONE WE WILL NOT RESOLVE, BECAUSE THE REGULATION DOES NOTThere is no table entry for nail polish remover. The classification follows the solvent, and the three realistic landing places are acetone, ethyl acetate and a generic flammable-liquids entry that requires the technical name in parentheses. Which one a given commercial remover ships as is a formulation-specific determination the regulation assigns to the shipper. We will not pick one for you, and anyone who does without the product in front of them is guessing.
A SPECIAL PROVISION ON TWO OF THESE THREE RAISES THE LIMITED-QUANTITY INNER-CONTAINER CAP FROM 1 L TO 5 L FOR GROUND. CARD 05.SP 149
3entries that cover most of it
UN1263the one nobody expects
II or IIIthe usual packing groups
How they position itThis is the level a storefront's operations lead actually works at, and almost no page in this category reaches it. An address that does is one they send to their 3PL.
03

The Exception That Names Cosmetics

Where most of the catalog quietly sits
🔒 cleangirlshop.com
173.150(g)70%5.6 L Read the exception

Under 70 percent
alcohol, in a small
enough bottle, it
leaves the regime.

One paragraph of the hazardous materials regulations names cosmetics expressly and excepts them outright. It is the single most commercially useful provision in this whole subject, it turns on container size and alcohol strength rather than on any ingredient, and almost nobody selling beauty products online knows it is there.

49 C.F.R. 173.150(g), “LIMITED QUANTITIES OF RETAIL PRODUCTS CONTAINING ETHYL ALCOHOL”VERBATIM
Beverages, food, cosmetics and medicines … containing not more than 70% ethyl alcohol by volume for liquids … are excepted from the HMR provided that …ELLIPSES OURS. THE WORD COSMETICS IS IN THE REGULATION.
NON-GLASS INNER PACKAGINGVolume does not exceed 0.47 liters. Between 0.47 L and 3.8 L the company name and the words “Contains Ethyl Alcohol” must be marked on the package.470 mL
GLASS INNER PACKAGINGVolume does not exceed 0.23 liters. Between 0.23 L and 0.47 L the same marking applies.230 mL
THE OUTER PACKAGENet liquid contents of all inner packagings may not exceed 5.6 liters, gross weight may not exceed 30 kilograms, and inner packagings must be secured and cushioned to prevent breakage, leakage and shifting.5.6 L / 30 kg
BY AIR, IT TIGHTENSNo outer package may be transported containing an inner packaging exceeding 0.47 liters of flammable liquid. Over 70 percent alcohol, the inner limit drops to 0.23 L for everything.AIR DIFFERS
WHAT THIS MEANS FOR A REAL CATALOG, STATED CAREFULLYA glass fragrance bottle up to 230 milliliters, or a plastic or metal one up to 470, in a box holding no more than 5.6 liters net and 30 kilograms gross, at 70 percent alcohol or under, is excepted from the hazardous materials regulations entirely. No hazard class, no identification number, no square-on-point mark. That is where most of a storefront's fragrance, toner and setting spray actually sits. Above those container sizes you add the company name and “Contains Ethyl Alcohol”. Above the larger bands you are back in the regime at UN1266.
THIS EXCEPTION DOES NOT REACH AEROSOLS, AND IT DOES NOT REACH ACETONE. CARDS 02 AND 04.SCOPE
70%the alcohol ceiling
230 mLglass inner container
5.6 Lnet per outer package
How they position itOne paragraph decides whether a fragrance line ships as ordinary parcels or as regulated freight. An address that prints it, with its limits, is the one a buyer bookmarks.
04

The Ban Is Not Where Everyone Thinks

What actually stops a parcel, and what does not
🔒 cleangirlshop.com
9APub 521 liter See the split

Transport law
allows hairspray on
a passenger plane.
The post office
does not.

The most repeated claim in shipping-compliance writing is that federal transport rules forbid flammable aerosols on passenger aircraft. They do not. Column 9A of the hazardous materials table reads 75 kilograms, and the air limited-quantity rules carve aerosols in by name. What actually stops a beauty storefront is the postal regulations and the carrier's private contract.

49 C.F.R. 172.101 COLUMN 9A AGAINST USPS PUBLICATION 52, AUGUST 2026 EDITIONCOUNTER-INTUITIVE
WHAT TRANSPORT LAW SAYSAllowed, with a limitColumn 9A for Aerosols, flammable reads 75 kg, not Forbidden; column 9B reads 150 kg. And the air limited-quantity rules exclude Division 2.1 “except Aerosols (UN1950) … without subsidiary risk” - the regulation carves aerosols back in by name. What IS forbidden on passenger aircraft: engine starting fluid, poison aerosols, and corrosive aerosols in packing group II.
WHAT THE POST OFFICE SAYSProhibitedPublication 52 on aerosols: “Domestic Mail via Air Transportation: Division 2.1 (flammable gases) and Division 2.3 (toxic gases) are prohibited.” On flammable liquids: “Domestic Mail via Air Transportation: Flammable liquids are prohibited” and “International Mail: Flammable liquids are prohibited.”
THE AEROSOL CEILING NOBODY EXPECTSPackaging Instruction 2A: “the total volume of flammable gas does not exceed 33.8 fluid ounces (1-liter) per mailpiece.” Not per can. Per parcel. Two ten-ounce hairsprays and the box is at its ceiling.1 L per parcel
ACETONE REMOVER IS NOT MAILABLE AT ALLPublication 52: “All flammable liquids having a flashpoint of 20 F or below are prohibited from mailing”, and “Acetone (UN1090) normally has a flashpoint of 0 F … nonmailable unless diluted … to raise the flashpoint to 20 F or higher.”NONMAILABLE
AND THE FAST SERVICE TIERS ARE OUTLimited quantity surface materials: “These materials are prohibited in Priority Mail Express and Priority Mail.”SURFACE ONLY
AND THE THIRD RULEBOOK, WHICH IS NOT LAW AT ALLThe two large parcel carriers publish their own hazardous materials terms. Those are contracts of carriage, not federal regulations: binding as terms between the carrier and the shipper, enforceable by the carrier, frequently stricter than the transport rules, and changeable by the carrier without a rulemaking. One of them accepts ground limited-quantity shipments without a contract and requires one for fully regulated materials; the other asks sellers to become approved hazardous materials shippers through an account representative. A storefront is complying with three rulebooks at once and only two of them are published by a government.
75 kgwhat column 9A actually says
1 literflammable aerosol per mailpiece
20 Fthe flash point that ends it
How they position itGetting this one backwards is the most common error in the category. The address that corrects it, with the column number and the postal section, is the one that gets cited.
05

No Paperwork, But You Are Trained

What the limited-quantity exception actually excepts
🔒 cleangirlshop.com
ReliefTraining25 mm See both halves

No shipping paper.
No placard.
No registration.
Training, tested,
documented.

Limited quantity is the route almost every beauty storefront ships on, and it is widely described as an exemption from the rules. It is not. It is a specific, enumerated list of reliefs with an equally specific list of duties left standing, and the duty most sellers have never heard of is a training record their employees are tested against every three years.

49 C.F.R. PARTS 107, 172 AND 173 · WHAT IS EXCEPTED AND WHAT IS NOTBOTH COLUMNS
RELIEF A LIMITED-QUANTITY SELLER GETSNo specification packaging. No labeling, except by air. No shipping paper, with four carve-outs. No placarding. No emergency response information. No 24-hour emergency telephone number. And no registration with the pipeline and hazardous materials agency, because every registration trigger runs through placarding, bulk packaging or materials a parcel never carries.6 RELIEFS
butstill owed
WHAT IS LEFT STANDINGCorrect classification. The limited-quantity packaging and gross-weight conditions. The square-on-point mark. And training: a person who prepares hazardous materials for transportation is a hazmat employee, a business that causes them to be transported is a hazmat employer, and there is no headcount threshold and no small-business exemption.4 DUTIES
THE RECORD, WHICH IS THE PART PEOPLE MISSThe employer “must create and retain a record of current training … for as long as that employee is employed … and for 90 days thereafter”, make it available to a federal official on request, and the record must name the employee, the completion date, the materials used, who trained them, and carry a certification that the employee has been trained and tested. Retraining at least once every three years.DOCUMENTED
AND SOMETHING NEW, AIMED AT EXACTLY THIS BUSINESSA rule effective September 3, 2026 lets a shipper put a reduced-size limited-quantity mark on the shipping label itself, “a minimum of 25 mm on each side”, instead of a 100 mm mark on the box. The agency's stated aim was to reduce costs for shippers of consumer products. Not for air. Not on an overpack.SEP 2026
A ONE-PERSON STOREFRONT BOXING NAIL POLISH IS SIMULTANEOUSLY THE HAZMAT EMPLOYER AND THE HAZMAT EMPLOYEE. THE REGULATION DEFINES BOTH TO INCLUDE THE SELF-EMPLOYED.BOTH AT ONCE
6reliefs granted
3 yearsretraining interval
25 mmthe new label mark
How they position itThe reliefs are what a seller hopes for and the duties are what an auditor asks for. An address that prints both columns is the one a serious operator trusts with the rest.
06

Thirty Days Is The Default, Not The Deadline

The rule that turns marketing copy into a legal obligation
🔒 cleangirlshop.com
435.230 days2 days Read the rule

Say two-day
shipping and you
have given yourself
two days.

The federal order rule gives a seller thirty days to ship only when the seller has said nothing. State a shipping time clearly and that stated time governs instead. Every storefront that puts a speed promise in its banner has shortened its own legal window, and most of them have never read the sentence that does it.

16 C.F.R. 435.2(a)(1), “MAIL, INTERNET, OR TELEPHONE ORDER MERCHANDISE”VERBATIM
… unless, at the time of the solicitation, the seller has a reasonable basis to expect that it will be able to ship any ordered merchandise to the buyer: (i) Within that time clearly and conspicuously stated in any such solicitation; or (ii) If no time is clearly and conspicuously stated, within thirty (30) days after receipt of a properly completed order from the buyer. Provided, however, where, at the time the merchandise is ordered the buyer applies to the seller for credit to pay for the merchandise in whole or in part, the seller shall have fifty (50) days, rather than thirty (30) days, to perform the actions required in this paragraph.ELLIPSIS OURS. EVERYTHING ELSE IS THE RULE'S OWN WORDS, INCLUDING THE PROVISO ALMOST NOBODY QUOTES.
WHEN THE CLOCK STARTS“Receipt of a properly completed order” is the time the seller receives both payment and an order containing all the information needed to process and ship it. Not when the payment clears. Not when the bank credits the account.BOTH
WHAT COUNTS AS SHIPPING“Shipment” is defined as “the act by which the merchandise is physically placed in the possession of the carrier.” Handing the parcel over is shipment. Printing a label is not.HANDOVER
THE INVERSIONA storefront advertising two-day shipping has not bought itself goodwill against a thirty-day rule. It has replaced the thirty-day default with a two-day obligation, in its own words, in its own banner.SELF-INFLICTED
HOW OLD THIS IS, AND WHY THAT MATTERSIt was promulgated in 1975 as the Mail Order Merchandise Rule, extended to telephone orders in 1993, reorganized in 2011, and amended and renamed in 2014 to confirm that it covers all internet merchandise orders regardless of how the buyer reaches the internet. There has been no amendment since. A storefront launched this year is operating under a rule older than the web, and the agency has said in terms that the same rules it enforced against catalog companies for fifty years apply to online sellers.
30 daysonly if you say nothing
50 daysif the buyer applies for credit
1975when the rule was written
How they position itEvery storefront writes a shipping promise into its homepage. Almost none of them know the promise is the operative legal standard. That gap is the whole value of this address.
07

Silence Means Two Different Things

The consent mechanics most sellers have backwards
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Under 30Over 30Renewed See the fork

Under thirty days,
silence is consent.
Over thirty days,
silence is
cancellation.

When a seller cannot ship on time it has to offer the buyer a choice, without being asked, before the deadline passes. What happens if the buyer never answers depends entirely on how long the delay is, and the default flips at thirty days. This is the single thing sellers get backwards most often.

16 C.F.R. 435.2(b) · THE DELAY OPTION AND WHAT SILENCE DOES TO ITTHE FORK
REVISED DATE 30 DAYS OR LESS LATERSilence is consentThe offer must expressly inform the buyer that “unless the seller receives … a response from the buyer rejecting the delay and cancelling the order, the buyer will be deemed to have consented” to shipment on or before the revised date.
MORE THAN 30 DAYS, OR NO DATE AT ALLSilence is cancellationThe offer must expressly inform the buyer that “the buyer's order will automatically be deemed to have been cancelled” unless the seller ships within thirty days of the original time and has had no cancellation, or receives the buyer's specific consent within that window.
THE OFFER ITSELFIt must be “clearly and conspicuously and without prior demand”, made within a reasonable time after the seller first knows it cannot ship, and “in no event later than said applicable time.” It must give a definite revised date, or say plainly that the seller cannot represent how long the delay will be.UNPROMPTED
IF THE REVISED DATE IS ALSO MISSEDA renewed option is required, and the default inverts: now the buyer “will be deemed to have rejected any further delay, and to have cancelled the order” unless they specifically consent.FLIPS AGAIN
AND THE SELLER PAYS FOR THE REPLYIt is a violation to “fail to furnish the buyer with adequate means, at the seller's expense” to exercise the option or notify the seller of cancellation.SELLER'S COST
A SUBSCRIPTION BOX'S FIRST SHIPMENT IS COVERED BY THIS RULE. LATER ONES ARE NOT - THE RULE EXCLUDES SERIAL DELIVERIES AFTER THE INITIAL SHIPMENT. CARDS 11 TO 15 ARE WHAT GOVERNS THOSE.THE HANDOFF
30 dayswhere the default flips
0demands required from the buyer
2times the offer must be made
How they position itA buyer who sells physical goods online needs this on a laminated card. Owning the address that explains the fork is owning the moment the operator realizes they had it backwards.
08

A Gift Card Is Not A Refund

The seven-working-day duty, and the two cases that enforced it
🔒 cleangirlshop.com
7 daysDefinedEnforced See the list

The rule lists what
counts. Store credit
is not on the list.

When an order is canceled because it never shipped, the seller owes a prompt refund, and the rule defines both words. Prompt means seven working days. Refund means one of five specific things, and a gift card or store credit is not among them. Two federal enforcement actions turned substantially on that exact substitution.

16 C.F.R. 435.1(b) AND 435.1(d) · WITH THE DISTINCTION STATED FIRSTREAD THE NOTE
THIS IS NOT A RETURNS POLICY, AND THE DIFFERENCE IS THE WHOLE POINTEverything on this card concerns merchandise the buyer ordered and the seller never shipped. It is a shipping-timing duty attached to an order the seller could not fill, not a rule about sending something back. A storefront's returns policy is a different subject governed by different instruments and this page does not touch it. We lead with the distinction because conflating the two is how sellers end up thinking a store credit discharges this duty.
PROMPT, DEFINEDA refund sent “by any means at least as fast and reliable as first class mail within seven (7) working days” of the date the buyer's right to a refund vests. One billing cycle instead, where the seller is itself the creditor.7 working days
REFUND, DEFINED EXHAUSTIVELYCash. Check. Money order. A credit memorandum removing the charge. Or instructions to the payment transferor to return the amount in the form it was tendered. That is the entire list.5 forms
ENFORCED, 2020An online fashion retailer paid $9.3 million over shipping-delay notices and for using gift cards to compensate buyers for unshipped merchandise. The agency's words: gift cards “are not considered refunds under the Mail Order Rule.” The settlement required it to ship within one day of an order whenever it does not specify a date.$9.3M
ENFORCED AGAIN, 2023A footwear seller paid $1.95 million, the order-rule counts being failure to issue delay notices, failure to cancel and refund after not issuing them, and “issuing consumers gift cards instead of sending prompt refunds.”$1.95M
WE NAME NO COMPANY ON THIS PAGE. THESE ARE PUBLISHED FEDERAL ENFORCEMENT OUTCOMES, DESCRIBED BY WHAT WAS CHARGED AND WHAT WAS PAID.NO NAMES
7working days
5forms that count as a refund
0of them a gift card
How they position itThe gift-card substitution is the most common informal practice in direct-to-consumer retail and it has been penalized twice. An address that says so plainly is doing a buyer a real service.
09

The Exposure Follows The Promise

Fifty years of enforcement, and what it keys on
🔒 cleangirlshop.com
200020202024 See the arc

The penalty tracks
what you said,
not what you sell.

The agency has brought these cases against catalog companies, against the first wave of online retailers, and against native direct-to-consumer brands. Reading them together, the size of the exposure has almost nothing to do with the product and almost everything to do with the specificity of the shipping promise and how often it was missed.

PUBLISHED FEDERAL ENFORCEMENT UNDER THE ORDER RULE · DESCRIBED, NOT NAMEDTHE ARC
JULY 2000Seven internet retailers settle over the 1999 holiday season for $1.5 million in civil penalties, for inadequate delay notices and for continuing to promise specific delivery dates when timely fulfillment was impossible. Individual penalties ran from $45,000 to $350,000; one seller's was waived down for financial condition and another was required to reimburse every buyer who had ordered and not received.
APRIL 2020An apparel seller pays $9.3 million. The conduct the agency quoted was its own copy: “Fast Shipping,” “2-Day Shipping,” “Expect Your Items Quick!” The promise created the obligation.
DECEMBER 2024A marketplace pays $2,013,527. It shipped 37 percent of orders on its instant tier and more than 16 percent of next-day orders late, while buyers paid $14.50 to $25 for the upgrade, and it did not offer the delay-or-cancel option.
The same rules that we have enforced for nearly 50 years against catalogers and other mail-order companies also apply to online sellers.A BUREAU DIRECTOR, QUOTED IN THE AGENCY'S OWN 2020 ANNOUNCEMENT
THE PATTERN, STATED WITHOUT EXAGGERATIONTwo of these three turned on a paid or advertised speed tier rather than on the goods. A seller that promises nothing specific has thirty days and a low bar. A seller that sells a shipping upgrade has sold a deliverable, and the published figures suggest the agency treats a missed upgrade as more serious than a slow order. None of this is about what was in the box.
LIMITATION PERIODS: THREE YEARS FOR CONSUMER REDRESS, FIVE FOR CIVIL PENALTIES, PER THE AGENCY'S OWN BUSINESS GUIDE.THE WINDOW
$1.5Mseven e-tailers, 2000
16-37%of upgraded orders shipped late
3 and 5years, the two limitation periods
How they position itA buyer sizing the risk of a storefront wants to know what actually gets penalized. Three dated outcomes with the conduct quoted is the most useful page in this category.
10

No Records, And You Carry The Burden

A rebuttable presumption that works like a recordkeeping rule
🔒 cleangirlshop.com
PresumptionGuideFive Read the catch

You are not
required to keep
records. You just
lose without them.

The order rule contains no recordkeeping requirement. It contains something sharper: two presumptions that shift the burden of proof onto any seller who cannot document its own systems. The agency's own guidance says so in plain words, and then lists the five records it expects to see.

16 C.F.R. 435.2(a)(4) AND 435.2(d), AND THE AGENCY'S OWN BUSINESS GUIDETHE CATCH
… the failure of a respondent-seller to have records or other documentary proof establishing its use of systems and procedures which assure the shipment of merchandise … will create a rebuttable presumption that the seller lacked a reasonable basis for any expectation of shipment within said applicable time.THE RULE'S OWN WORDS. A SECOND, IDENTICAL PRESUMPTION COVERS THE NOTICE AND CANCELLATION DUTIES.
Although you are not required to keep records … if you cannot document your use of systems and procedures for complying, the Rule provides that you bear the burden of proving you do comply.THE AGENCY'S BUSINESS GUIDE, QUOTED. ELLIPSIS OURS. THE RULE CONTAINS 0 RECORDKEEPING REQUIREMENTS AND 2 PRESUMPTIONS THAT MAKE THAT IRRELEVANT.
THE FIVE RECORDS NAMEDThe date the order was received. The contents of and date of any delay-option notice. The date any cancellation was received. The date of any shipment and what was shipped. The date of any refund and what it was for.5
AND WHAT IT DOES NOT PREEMPTThe rule does not annul state or local rights or remedies that are “equal to or greater than” those it provides, and supersedes only provisions that are inconsistent with it and weaker. A seller clears the federal bar and still has fifty other floors to check.FLOOR, NOT CEILING
WHY THIS IS THE RIGHT CARD TO END THE LANE ONA presumption that shifts the burden is worth more to a regulator than a recordkeeping rule, because it costs nothing to enforce and it bites exactly the sellers least able to answer. A storefront with an order-management system that timestamps these five things has a defense. A storefront running on spreadsheets and screenshots has an argument. The rule never tells anyone to keep records, and that is precisely what makes it dangerous.
2rebuttable presumptions
5records the agency names
0recordkeeping requirements
How they position itThe absence of a requirement that functions as a requirement is the kind of finding that makes an operator forward a link. That is what this address is for.
11

The Rule Everyone Cites Was Vacated

A federal rule struck down six days before it bit
🔒 cleangirlshop.com
20242025Whole Read the holding

Struck down whole.
Six days before
its own compliance
date.

The click-to-cancel rule is still quoted as current in much of the writing about subscription commerce. A federal appeals court vacated it in its entirety in July 2025, on a procedural failure, and the agency removed the text from the regulations in February 2026. Any citation to its operative sections describes a rule that does not exist.

EIGHTH CIRCUIT, PER CURIAM, FILED JULY 8, 2025 · 142 F.4th 1060VACATED
NOV 15, 2024The final rule is published. Effective January 14, 2025; regulated entities have until May 14, 2025 to comply with its operative sections.
MAY 2025The agency defers compliance to July 14, 2025 by enforcement discretion.
JUL 8, 2025The court grants the petitions and vacates the rule. The compliance date was never reached.
FEB 12, 2026The agency revises the regulation to restore the pre-2024 text. The operative sections are gone from the code.
… vacatur of the entire Rule is appropriate in this case because of the prejudice suffered by Petitioners as a result of the Commission's procedural error … we grant the petitions for review and vacate the Rule.THE OPINION, QUOTED. ELLIPSES OURS.
THREE THINGS THE COURT SAID THAT ALMOST NOBODY REPEATS, AND ALL THREE CUT AGAINST THE EASY READINGIt decided one procedural question - a missing preliminary regulatory analysis after an administrative law judge found the rule would exceed a hundred million dollars in economic effect - and expressly declined the rest: “we need not address Petitioners' other substantive challenges to the Rule.” It found no bad faith, saying the decision to bypass the analysis was “certainly not made in bad faith or an outright dodge of APA procedures.” And it volunteered that it does “not endorse the use of unfair and deceptive practices in negative option marketing.” This was a paperwork failure, not a holding that the agency lacks power or that subscription traps are lawful.
THE RULE'S OWN SEVERABILITY CLAUSE WAS CONSIDERED BY NAME AND REJECTED, AS WAS THE AGENCY'S REQUEST FOR A PARTY-SPECIFIC VACATUR. WHOLE, NOT PART.ENTIRE
2025-07-08vacated
6days before compliance
0sections left standing
How they position itHalf the writing on subscription commerce is now wrong, and confidently so. Being the address that is right, with the docket and the dates, is a durable position.
12

What Is Left Is The Book Club Rule

A 1973 rule that reaches twenty-five sellers
🔒 cleangirlshop.com
197325Prenotification Read what remains

The rule in force
was written for
mailing a form back.

Vacating an amendment reinstates what it replaced, so the regulation now in force is the one promulgated in 1973 for prenotification plans. It still speaks of mailing a form and guaranteeing return postage. The agency's own estimate of how many sellers it reaches, nationwide, is twenty-five.

16 C.F.R. PART 425 AS IT READS TODAY · SOURCE NOTE 91 FR 6509, FEBRUARY 12, 2026CURRENT TEXT
Title of the part today“Use of Prenotification Negative Option Plans”RESTORED
Sections that exist425.1 The rule, and 425.2 [Reserved]2
Sections people still cite425.3, 425.4, 425.5, 425.6 and 425.90
Sellers subject to it, on the agency's own 2024 estimatedescribed in its words as “clubs”25
The Rule applies only to prenotification plans for the sale of goods and does not reach most modern negative option marketing.THE AGENCY, IN ITS MARCH 2026 RULEMAKING NOTICE
WHAT A PRENOTIFICATION PLAN ACTUALLY IS, AND WHY A BEAUTY BOX IS NOT ONEThe definition requires the seller to periodically send an announcement identifying merchandise it proposes to send, which the subscriber then receives and is billed for unless they instruct the seller not to send it. The announcement comes first and the shipment follows the silence. A subscription box bills on a schedule and ships what it chooses; nothing is announced for refusal in advance. The agency says so itself: the current rule does not cover continuity plans, automatic renewals or trial conversions.
THE AGENCY HAS NOT WALKED AWAY. IT OPENED A NEW PRELIMINARY RULEMAKING NOTICE ON MARCH 13, 2026, COMMENTS CLOSED APRIL 13, AND AS OF OUR SEARCH NO PROPOSED RULE HAS FOLLOWED. WE PREDICT NOTHING.RESTARTED
1973the rule now in force
25sellers it reaches
2sections that survive
How they position itA storefront operator who reads one article and concludes the rules are gone is about to make an expensive mistake. Card 13 is why, and this address is where both halves sit together.
13

The Statute Never Went Anywhere

Why the vacatur changed almost nothing for an online seller
🔒 cleangirlshop.com
84038404Penalty Read the statute

The rule died in
July. In September
the statute produced
a billion dollars.

A 2010 statute makes it unlawful to charge anyone online through a negative option feature without three specific things, and it deems a violation to be a violation of a federal trade rule in its own terms. Congress pre-loaded the enforcement mechanism, so no rule was ever needed. Two and a half months after the rule was struck down, that statute produced the largest civil penalty ever obtained in a rule-violation case.

15 U.S.C. 8403, RESTORE ONLINE SHOPPERS' CONFIDENCE ACT · QUOTED COMPLETESTILL LAW
It shall be unlawful for any person to charge or attempt to charge any consumer for any goods or services sold in a transaction effected on the Internet through a negative option feature … unless the person - (1) provides text that clearly and conspicuously discloses all material terms of the transaction before obtaining the consumer's billing information; (2) obtains a consumer's express informed consent before charging … and (3) provides simple mechanisms for a consumer to stop recurring charges …ELLIPSES OURS. THE THREE NUMBERED DUTIES ARE COMPLETE AND UNEDITED.
WHY IT HAS TEETH WITHOUT A RULEThe next section provides that a violation “shall be treated as a violation of a rule” on unfair or deceptive acts, which is what unlocks civil penalties. The agency's own words: Congress “did not require the FTC to create regulations” to enforce it.PRE-LOADED
SEPTEMBER 25, 2025A stipulated order against a large online retailer: $1 billion civil penalty plus $1.5 billion in consumer redress. The agency called the penalty the largest ever in a case involving one of its rule violations. The conduct alleged was interface design that enrolled people in auto-renewing subscriptions and a cancellation process whose “primary purpose … was not to enable subscribers to cancel, but to stop them.”$2.5B TOTAL
JUNE 2026, ELEVEN MONTHS AFTER THE VACATURA new enforcement action against a fifteen-company enterprise, alleging obscured references to recurring charges, cancellation options omitted from sites and apps, and charges continuing after cancellation was confirmed.STILL FILING
THE SENTENCE TO HANG THE WHOLE LANE ON, IN THE AGENCY'S OWN WORDS“ROSCA is the only Federal law primarily designed to regulate negative option marketing, but it is limited to seller transactions effected on the internet.” For an online beauty storefront that limit is no limit at all. The rule was the belt. The statute is the trousers, and it was never removed.
THE $2.5 BILLION IS NOT A FINE. IT IS A ONE BILLION DOLLAR CIVIL PENALTY PLUS ONE AND A HALF BILLION IN CONSUMER REDRESS, AND THE DISTINCTION IS THE AGENCY'S OWN.PRECISE
3things the statute requires
$1Bcivil penalty, Sept 2025
2026a new case filed under it
How they position itThis is the correction the whole category needs and almost nobody has published. An address that carries it is one a compliance lead and a founder both cite.
14

One State Wrote The Phrase Into Law

Where the words click to cancel actually appear
🔒 cleangirlshop.com
CANYNYC See the map

California's statute
says click to cancel.
New York's bill died.
New York City's
rule starts today.

With the federal rule gone, the binding requirements are a federal statute and whatever state and local law reaches the seller. One state put the exact phrase in its code. A second is widely assumed to have done the same and did not. And a city rule carrying that name takes effect the day this page went up.

CALIFORNIA BUS. & PROF. CODE 17600 ET SEQ, NEW YORK GEN. BUS. LAW 527-a, AND 6 RCNY 5-110THREE LAYERS
CALIFORNIAThe statute itself requires that a save offer online display a continuously and proximately shown link or button“click to cancel”IN THOSE WORDS, IN THE CODE. A BUSINESS THAT LETS YOU SIGN UP ONLINE MUST LET YOU TERMINATE EXCLUSIVELY ONLINE, AT WILL, WITHOUT STEPS THAT OBSTRUCT OR DELAY.
CALIFORNIA, THE DATESIts 2024 amendments were effective January 1, 2025Jul 1, 2025BUT BOTH AMENDED SECTIONS APPLY ONLY TO A CONTRACT ENTERED INTO, AMENDED OR EXTENDED ON OR AFTER JULY 1, 2025. GIVE BOTH DATES OR NEITHER.
NEW YORKHas an automatic renewal statute, amended in 2023 to add a renewal notice fifteen to forty-five days before the cancellation deadlinenoBUT NO CLICK-TO-CANCEL LAW. THAT BILL DIED IN THE SENATE ON JANUARY 7, 2026; ITS COMPANION IS STILL IN COMMITTEE. ASSUMING OTHERWISE IS A LIVE TRAP.
NEW YORK CITYAn agency rule, not a council statute, adopted by the consumer protection department under the city charterOct 1, 2026CANCELLATION MUST BE AS EASY AS THE MECHANISM USED TO CONSENT, AND THROUGH THE SAME MEDIUM. PENALTIES $525 FIRST, $1,050 SECOND, $3,500 THIRD AND AFTER.
HOW MANY STATES HAVE ONE OF THESE, AND WHY WE WILL NOT TELL YOUWe read two state statutes to their operative text and that is the number we will stand behind. No federal or interstate body publishes a count. The federal agency had every reason to give one in its own 2026 rulemaking notice and deliberately did not, writing instead of “an assortment of State laws” providing “varying levels of protection” and naming four by citation with no total. Every integer in circulation depends on an unstated choice about whether to count narrow sector statutes written decades earlier.
2026-10-01the city rule takes effect
$525its first-violation penalty
2026-01-07the day the state bill died
How they position itA storefront with national customers is subject to all three layers at once and most operators know about the one that was struck down. That inversion is the opportunity this address sells.
15

Ship It Without Consent And It Is A Gift

The remedy that should end every subscription conversation
🔒 cleangirlshop.com
17603GiftSafe harbor Read the remedy

The goods become
an unconditional gift.
You pay the return
shipping. There is
no return.

Most consumer statutes answer a violation with a penalty. California's answers one with a transfer of title. If a business sends goods under a continuing agreement without first obtaining affirmative consent, the statute converts them into a gift to the recipient, and says so in terms that leave nothing to argue about.

CALIFORNIA BUSINESS AND PROFESSIONS CODE 17603 · QUOTED IN FULLTHE REMEDY
In any case in which a business sends any goods, wares, merchandise, or products to a consumer, under a continuous service agreement or automatic renewal of a purchase, without first obtaining the consumer's affirmative consent … the goods, wares, merchandise, or products shall for all purposes be deemed an unconditional gift to the consumer, who may use or dispose of the same in any manner he or she sees fit without any obligation whatsoever on the consumer's part to the business, including, but not limited to, bearing the cost of, or responsibility for, shipping any goods … to the business.ELLIPSES OURS. EVERYTHING ELSE IS THE STATUTE.
WHY THIS LANDS HARDEST ON A GOODS BUSINESSA services subscription that gets consent wrong owes a refund. A physical-goods subscription that gets it wrong has given its inventory away, cannot ask for it back, and cannot charge for the shipping it already paid. The remedy scales with cost of goods, not with the price of the plan.INVENTORY
AND THE SAFE HARBOR, WHICH IS REALThe same article provides that a business which complies with it in good faith “shall not be subject to civil remedies”, and that a violation is not a crime. The exemptions - utilities, insurers, alarm operators, financial institutions, service contract sellers - reach none of this.GOOD FAITH
THE RECORD THAT PROVES CONSENTVerification of consent must be kept “for at least three years, or one year after the contract is terminated, whichever period is longer.” Same shape as card 10: the duty is not to have consent, it is to be able to show it years later.3 years
CANCELLATION MUST BE AVAILABLE IN THE SAME MEDIUM THE CONSUMER USED, AND A PHONE LINE THAT GOES TO VOICEMAIL MUST PROCESS OR CALL BACK WITHIN ONE BUSINESS DAY.SAME MEDIUM
1sentence
0obligation on the recipient
3 yearshow long consent must be kept
How they position itA single sentence that converts unsold inventory into a gift is the most memorable fact in this subject. It is the one a buyer repeats, and it arrives at this address.
16

There Is No Federal Sales Tax

What the Supreme Court actually decided, and what it did not
🔒 cleangirlshop.com
2018ThresholdsStates Read the case

The Court set
no threshold.
And the state that
won repealed half
of its own.

The 2018 decision that ended the physical-presence rule is routinely described as establishing a hundred thousand dollar standard. It did nothing of the kind. It overruled two cases, described one state's statute as unlikely to discriminate, remanded everything else, and told Congress it could legislate. The state whose law it reviewed has since repealed the transaction prong the Court quoted.

SOUTH DAKOTA v. WAYFAIR, INC., 585 U.S. 162, DECIDED JUNE 21, 2018 · AND WHAT HAPPENED NEXTPRIMARY SOURCE
Quill Corp. v. North Dakota … and National Bellas Hess, Inc. v. Department of Revenue of Ill. … are overruled.THE OPERATIVE SENTENCE, QUOTED EXACTLY. ELLIPSES REPLACE THE CITATIONS.
WHAT THE STATUTE SAID, AS THE COURT QUOTED ITThe act applied only to sellers that “deliver more than $100,000 of goods or services into the State or engage in 200 or more separate transactions” annually. That is one state's legislature, quoted by the Court. It is not a holding.ONE STATE
WHAT THE COURT ACTUALLY DID WITH ITIt listed three features making the act unlikely to discriminate, then left the rest open: “Any remaining claims regarding the application of the Commerce Clause … may be addressed in the first instance on remand”, and handed the problem on: “Congress may legislate to address these problems if it deems it necessary and fit to do so.”REMANDED
AND THE PART NOBODY PRINTSThat state repealed the two-hundred-transaction criterion effective July 1, 2023. The statute the Court blessed no longer exists in the form the Court blessed it. At least seven other states have dropped the transaction prong since 2018, on dates from 2019 to 2025.REPEALED
HOW MANY STATES REQUIRE COLLECTION, AND THE ONLY NUMBER WE WILL STAND BEHINDThe federal audit office reported that as of June 2021, all forty-five states with a statewide sales tax and the District of Columbia had adopted requirements based on economic rather than physical presence. We print that figure with its as-of date and we do not restate it as a current fact, because the threshold detail in the same report is already demonstrably stale. Every bare current count in circulation comes from a compliance vendor's tracker, and we will not launder one into a statistic. One state's own revenue department currently publishes guidance quoting a threshold statute its legislature repealed - which is the best single argument for not trusting a tracker.
THERE IS NO FEDERAL SALES TAX AND NO FEDERAL SALES TAX REGISTRATION. EVERY COLLECTION DUTY ON THIS PAGE WAS CREATED BY A STATE.THE STRUCTURE
2018-06-21the decision
0national thresholds set
2023-07-01when the winner repealed its own
How they position itA storefront's first tax conversation starts from a number the Supreme Court never set. An address that corrects that, and shows the winning state walking it back, is the one that gets forwarded to the accountant.
17

The Marketplace Does Not Cover You

Two states, two opposite duties, one seller
🔒 cleangirlshop.com
ForbiddenCountedBoth See the trap

One state forbids
you to collect.
Another counts
those same sales
against you.

Selling through a marketplace is widely understood to hand the tax problem to the marketplace. It hands over the remittance. It does not hand over the seller's own position, and in at least one large state the volume the marketplace handled is what pushes the seller over the registration line for the sales the marketplace never touched.

VA. CODE 58.1-612.1(D) (2019, cc. 815, 816, 854) AND CALIFORNIA'S MARKETPLACE FACILITATOR ACT, R.&T. CODE 6040-6049.5, ADDED BY STATS. 2019, CH. 5, OPERATIVE OCTOBER 1, 2019 · READ OCTOBER 1, 2026THE TRAP
ONE STATE FORBIDS ITYou may not collectThe facilitator “shall be considered a dealer … and shall collect the tax … on all transactions that it facilitates”, and then the mirror image: “No marketplace seller shall collect sales and use tax on a transaction made through a marketplace facilitator's marketplace.” The seller is not merely excused. It is prohibited.
ANOTHER COUNTS THEMThey push you overThe facilitator becomes the retailer, and the facilitated sales still count toward the seller's own threshold. The seller must include all sales for delivery in the state, including sales facilitated through a marketplace, in deciding whether it has crossed $500,000 and must register in its own right.
THE EXPOSURE THAT CREATES, STATED PLAINLYA seller can be fully compliant on the marketplace and delinquent on its own checkout, because of the marketplace sales. The platform remits on what it handled and simultaneously builds the seller's registration obligation for everything it did not. Nobody sends an invoice for that. It surfaces in an audit, years later, on the direct-to-consumer orders the operator thought were too small to matter.
WHAT THE SELLER STILL OWES EVEN WHERE THE FACILITATOR REMITSOne state's statute requires the seller to retain records for all marketplace sales and to furnish the facilitator the information needed to collect correctly. Another's conditions the facilitator's liability relief on exactly that, so an error traceable to the seller's data comes back to the seller.RECORDS
THE SIMPLIFICATION AGREEMENT, COUNTED CAREFULLYIts own governing board says twenty-four states have adopted the Agreement. Its FAQ page says twenty-four full members and then enumerates twenty-three, naming one more as the only associate member. We print the board's own sentence and note the discrepancy rather than resolving it.24
EVERY STATE WE CHECKED THAT DROPPED THE TRANSACTION PRONG IS A MEMBER OF THE UNIFORMITY AGREEMENT. THAT IS OUR OBSERVATION ABOUT A PATTERN, NOT A SOURCED FINDING, AND WE LABEL IT AS ONE.LABELED
$500,000the threshold those sales count toward
0tax the seller may collect in one state
2019-10-01when California's regime went operative
How they position itThis is the failure mode that surfaces in an audit rather than at checkout. An address that names it before it happens is worth the price on that card alone.
18

The Same Bottle, Three Answers

Where a definition beats a federal label
🔒 cleangirlshop.com
ExemptTaxable6.25x See the split

Sunscreen is a drug
federally. Three states
disagree about what
that means for tax.

The federal drug regulator treats sunscreen as a drug. For sales tax, that fact does different work in different places: two states exempt it because of the federal label, a group of states tax it under a definition written to override that label, and one charges it more than six times the rate it charges a medicine.

FOUR STATE SOURCES, READ OCTOBER 1, 2026 · ONE PRODUCT, THREE TREATMENTSTHE HINGE
TWO STATES, EXEMPTOne exempts over-the-counter drugs labeled with a federal drug facts panel and lists sunscreen among the examples. The other lists sunscreens as exempt medicinal products, while suntan products containing no sunscreen stay taxable.0%THE EXEMPTION KEYS TO THE FEDERAL LABEL. THE ACTIVE INGREDIENT'S REGULATORY STATUS DOES THE WORK.
THE AGREEMENT STATES, TAXABLEA grooming and hygiene product is defined to include “sun tan lotion or screen, regardless of whether the item meets the definition of over-the-counter drug”, and the definition of over-the-counter drug expressly excludes grooming and hygiene products.TAXEDTHE CARVE-OUT IS DELIBERATE AND WRITTEN ON THE FACE OF THE DEFINITION. WE QUOTE IT AS ONE STATE RESTATES IT, NOT FROM THE AGREEMENT ITSELF, BECAUSE THAT IS THE TEXT WE READ.
ONE STATE, BOTH AT ONCENonprescription medicines get a one percent rate and general merchandise pays six and a quarter. Since September 1, 2009 the phrase nonprescription medicines and drugs “does not include grooming and hygiene products”, which pay the high rate “regardless of whether the products make medicinal claims.”1% vs 6.25%NAMED IN ITS AUDIT MANUAL'S HIGH-RATE LIST: SHAMPOOS AND HAIR CARE, TOOTHPASTE, ANTIPERSPIRANTS, SUNSCREENS, SOAPS, DEODORANTS, SKIN CREAMS AND LOTIONS.
WHY A STOREFRONT SHOULD CARE ABOUT A DEFINITION FIGHTBecause the line is not drawn by anything about the product. The same bottle, the same label, the same active ingredient, lands in three places because three sets of drafters chose differently about whether a federal designation should carry across. A catalog that spans sun care, cleansers, toothpaste and skin treatment is sitting on that line in several directions at once, and no part of it can be resolved by reading the ingredient list.
MENSTRUAL PRODUCTS SHOW THE SAME PATTERN AND WE PRINT NO NATIONAL COUNT: ONE STATE ZEROES ITS STATE RATE BUT KEEPS LOCAL TAXES, AND ONE STATE'S EXEMPTION EXPIRES ON DECEMBER 31, 2028 BY ITS OWN TERMS.NO COUNT
2states that exempt it
6.25xthe rate differential in one state
1definition doing all the work
How they position itNobody expects a tax card to be the interesting one. A single product landing three different ways on a definition is the kind of finding a buyer remembers and repeats.
19

Three Things Nobody Counts

The federal file, the register, and this name's own demand
🔒 cleangirlshop.com
NAICSCensusDemand See all three

No code for selling
online. No federal
figure for this
category. And no
demand for this
exact phrase.

Three negatives belong on this page and the third one is about the name itself. The federal classification system deleted the category for selling online. The statistical agency publishes no e-commerce figure for beauty retail. And the exact words in this domain have no measurable search demand, which we print because a buyer will find it in ten minutes if we do not.

CENSUS 2022 NAICS, THE 2022 ECONOMIC CENSUS, THE TRADEMARK REGISTER, AND OUR OWN TRENDS PULLTHREE NEGATIVES
2022 classification titles containing “Electronic Shopping”, “Mail-Order” or “Nonstore”the entire 454 subsector was deleted; its establishments were redistributed0
Industries the old online-and-mail-order code was split acrossour count from the official concordance42
E-commerce sales published for health and personal care retail, 2022the cell reads D: withheld to avoid disclosing individual companiesD
Cosmetics sales line in the annual retail surveyit publishes pharmacies and optical goods, and no cosmetics line at all0
Trademark records for this exact wording, across six indexeswordmark, both words any order, closed up, pseudo-mark, mark description, goods0
FIVE TERMS, US, ONE SHARED 0 TO 100 SCALE, 262 WEEKS TO OCT 3, 2026 · PEAK INDEX. THE FIFTH IS THE WORDING IN THIS DOMAIN, WHICH WE DO NOT PRINT BROKEN APART
100281631
beauty shopmakeup shopskincare shopclean beauty shopthis exact phrase
WEEKS AT ZERO, THE FOUR GENERIC TERMS0 of 262, each
WEEKS AT ZERO, THE PHRASE IN THIS DOMAIN250 of 262
ITS HIGHEST WEEK IN FIVE YEARS1
THE FINDING THAT CUTS AGAINST THIS DOMAIN, PRINTED BECAUSE IT IS TRUENobody searches this exact string. The demand sits in the four generic terms behind it, none of which ever read zero in five years. What that means commercially is a judgment for the buyer, not for us: a name can be worth owning because it is memorable, spellable and brandable rather than because it matches a query, and none of the four generic terms above is available as a dot com to anyone. But if the thesis was search traffic to the exact phrase, the data says no, and we would rather you read that here than discover it after. Index values only, never a search count, and no value here may be compared with one from any other comparison set. Two of the generic terms are ambiguous: one of them names a hair salon as often as a store.
THE PHRASE IS NOT AN ENTRY IN THE TRADEMARK OFFICE'S GOODS MANUAL EITHER. THE STANDING WORDING FOR THIS BUSINESS IS A TEMPLATE: ON-LINE RETAIL STORE SERVICES FEATURING, THEN YOU FILL IN THE FIELD.A TEMPLATE
02022 codes for selling online
250 of 262weeks this phrase reads zero
0records for the phrase as a mark
How they position itA seller who publishes the number that argues against their own asking price is telling a buyer exactly how much to trust everything else on the page. That is the trade this card makes.
20

What This Page Will Not Say

The claims we refused, published so they can be checked
🔒 cleangirlshop.com
MethodRefusalsSources See the list

Twelve things
we would not
put in print.

Every figure here names its source and its date. These are the statements that could not be made that way, so they are not made at all, and the list is published so a buyer can hold us to it.

DELIBERATE OMISSIONS · PUBLISHED SO THEY CAN BE CHECKEDNOT STATED
01Any market size for beauty, online beauty, clean beauty or subscription commerce. No federal series measures any of them. The e-commerce figure for health and personal care retail is suppressed for disclosure, the annual survey carries no cosmetics line, and the only adjacent figure bundles drugs and health aids with beauty aids and cannot be split. Card 19 prints the suppression instead of a number.
02That the click-to-cancel rule is in force, or that its sections require anything. It was vacated in full on July 8, 2025 and its text was removed from the regulations on February 12, 2026. Sections 425.3 through 425.6 and 425.9 do not exist. Equally, never that nothing binds online sellers now - the 2010 statute always did, and produced a billion dollar civil penalty two and a half months after the vacatur.
03That the courts held the agency lacks power over subscriptions, or that only part of the rule fell. The court decided one procedural question, expressly declined the substantive challenges, found no bad faith, and rejected both the rule's own severability clause and a party-specific vacatur by name.
04That New York requires click to cancel. That bill died in the Senate on January 7, 2026. California is the state whose statute contains the literal words. Transplanting one state's rule onto another is the most available error in this subject.
05Any count of how many states have an automatic renewal statute, or a current count of states imposing economic nexus. We read two renewal statutes in full and that is the number we stand behind; the federal agency itself declined to give a total and wrote “an assortment of State laws”. For nexus, the only government figure carries an as-of date of June 2021 and we print it with that date.
06That the Supreme Court set a $100,000 threshold. It quoted one state's statute, listed features making that statute unlikely to discriminate, remanded the rest and invited Congress to legislate. That state has since repealed half of what the Court quoted.
07Any uncollected-sales-tax figure. The widely repeated ones come from a party's own litigation brief quoted by the Court, are pre-2018 data, and are superseded by the audit office's own later collections estimate. We print none of them.
08That transport rules forbid flammable aerosols on passenger aircraft, or that limited quantity means exempt from the rules. Column 9A reads 75 kilograms and the air rules carve aerosols in by name; what stops a parcel is the postal regulations and the carrier's contract. And limited quantity is a list of six specific reliefs with four duties left standing, including training. Cards 04 and 05.
09That the phase-out of the old consumer-commodity marking happened in 2013 or 2014. The air sunset was December 31, 2012, the ground sunset was December 31, 2020, and every reference was struck from the regulations effective January 26, 2023. All three dates or none.
10Any seller-side duty we could not pin to the person it binds. Child-resistant packaging thresholds catch three ordinary beauty products, but we did not close the question of whether they bind a reseller who does not repackage, so this page states the thresholds and not a duty. The net-quantity rules for cosmetics run through the food and drug regulations, not the trade commission's packaging part, and a page citing the latter for a cosmetic is wrong.
11Any named company, registrant, applicant, attorney or examiner characterized in any way. The enforcement outcomes on cards 08, 09 and 13 are described by what was charged and what was paid, without naming the parties. Trademark records are reported as dates, classes and status. An abandoned application is a docketing fact and not a failure, and we did not read the office actions, so we say nothing about why anything was refused or suspended.
12Any conclusion about whether this name is registrable or available, in either direction. A blank register is not clearance, because common-law rights need no registration and are not in that index. We did not search phonetic variants, design marks, state registrations or foreign rights. Clearance is counsel's work.
EVERY NUMBER ON THIS SITE CARRIES ITS SOURCE AND ITS DATE, AND WHERE A FIGURE IS OUR OWN COUNT OR PARSE RATHER THAN A PUBLISHED STATISTIC, THE CARD SAYS SO.THE STANDARD
12refused claims
0market-size figures
0unsourced numbers
How they position itThe omissions list is the strongest sales asset on the page. It tells a buyer exactly what kind of operator built this and what standard the address already carries.
Own it

Twenty use cases.
One transaction.

The domain is listed through GoDaddy, which holds the funds and moves the name into your account. You are not wiring money to a stranger and you are not waiting on an escrow agent.

1

Buy it now

Click through to the listing and complete the purchase at the listed price. No negotiation and no waiting on a reply.

2

GoDaddy moves the name

GoDaddy holds the funds, pulls the domain from the seller's account and pushes it into yours. Typically same day for a buy it now.

3

Point it at your business

Change the nameservers and it resolves wherever you want: a new site, your existing site, or a redirect while you build.