US professional-use cosmetics: MoCRA labeling expectations still apply

Official English from FDA cosmetics pages and the MoCRA overview. FDA.gov prevails.

Under the FD&C Act, articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance are cosmetics (other than soap, as defined by FDA). FDA’s cosmetics pages apply that definition to products regardless of the retail channel described on the label.

FDA’s MoCRA overview states that facility registration, product listing, safety substantiation and serious adverse event reporting apply to cosmetic products as described in the statute, subject to the exemptions FDA lists on that page. The page does not create a “professional-use only” carve-out in those headings.