The disclosure failed
On this page9
The printed address does not resolve
The label went to print before the ingredient page existed, and the page never got built, or it moved. Fifty thousand labels now point at nothing and there is no way to fix them except a reprint.
The page is a year behind the formula
The commonest failure. A reformulation went through, the batch sheet changed, and the website was not part of anybody’s release checklist. The label is accurate for stock on shelves and the site is accurate for nothing.
The toll-free number is not toll-free
Or it rings out, or it is a mobile. The requirement names a toll-free number specifically, and the cost of one is small compared with reprinting a label that does not carry a valid one.
The list is incomplete
Processing aids, preservatives and pH adjusters left off because they are not what the product is about. An intentionally added ingredient is anything added for a functional or technical effect, which includes all three.
The fragrance supplier never answered
And the list went up without the detail, on the basis that it would be filled in later. It never is, and the gap is visible to anybody comparing your page against the statute.
Nothing announces any of this
There is no bounced email and no failed build. A wrong disclosure looks exactly like a right one until somebody checks, which is what makes it worth checking on a schedule.
Make it part of the release
A formula change that does not update the ingredient page is an incomplete release, in the same way that shipping without a label would be. Writing that into the process is the only thing that reliably works.
And hold the data once
Ingredients, CAS numbers and functional purposes in one file, rendered to the page and read by whoever writes the label. Two hand-maintained copies of the same list will disagree, and the disagreement will be invisible.