US MoCRA for SME cosmetic brands
MoCRA expanded FDA’s cosmetics authority: facility and product listing, safety substantiation, serious adverse event reporting, and a still-moving rulemaking calendar.
FDA
US PFAS: FDA wrote a data-gap report; states are writing bans
December 2025 FDA report ≠ permission. Illinois HB 3409 is the 2026 reminder that the calendar is state-by-state.
Illinois Cosmetic Products Act (HB 3409): state chemical list with a 2028 horizon
Illinois moved HB 3409 as a Cosmetic Products Act restricting listed chemicals, including PFAS, with a 1 July 2028 horizon in contemporary bill text. Confirm the Public Act before you brief retailers.
New ingredients, three doors: China NCI, EU annex, US substantiation
A “new INCI” is not one global project. China wants No. 59. The EU wants an annex path or a documented history. The US wants safety substantiation and a listing that matches the label.
MoCRA 2026 status board: live duties vs leftover rules
Listing and serious AE reporting are live. GMP, allergen labeling and the asbestos method are still a calendar. Brief the board with two columns.
FDA Voices (2026): MoCRA implementation progress — treat as a status board
FDA’s May 2026 Voices post walks listing, PFAS report, and leftover rulemakings. Useful as a checklist against the MoCRA statute page.
US MoCRA listing: what lean brands should confirm this quarter
Facility and product listing are live MoCRA duties. Rulemakings can slip; listing updates cannot wait for a perfect GMP rule.
FDA PFAS-in-cosmetics report (29 Dec 2025): data gap, not a federal ban
FDA’s MoCRA-mandated PFAS report found evidence too thin for safety determinations on most intentionally added PFAS. State bans can still apply.
US professional-use cosmetics: MoCRA labeling expectations still apply
“Salon only” is not a MoCRA off-ramp. Adverse-event contact and other required statements still need a home on the pack or the mandated alternative.
FDA withdrew the proposed asbestos test method for talc cosmetics (28 Nov 2025)
The December 2024 proposed rule on standardized asbestos testing in talc cosmetics was withdrawn. MoCRA still directs FDA to work this problem — a withdrawal is not a permission slip.