US Last reviewed: 2026-08-12

US MoCRA for SME cosmetic brands

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is the largest expansion of FDA cosmetics authority since the FD&C Act: listing, safety substantiation, adverse events, and further rules still being written.

Who should care

US and foreign brands selling cosmetics in the United States, contract manufacturers, and facility owners. Some small-business exemptions exist — verify on FDA pages, do not assume you are out of scope.

Competent authority: U.S. Food and Drug Administration (FDA)

Official sources

SME: first 5 things

  1. 1
    Confirm you are in scope

    Most cosmetics in US commerce are; check FDA definitions and any small-business exemptions.

  2. 2
    Keep facility listing current

    Manufacturing/processing facilities must be listed and updated after material changes.

  3. 3
    Keep product listing current

    List marketed products and refresh when formula, brand, or facility data change.

  4. 4
    Build a serious adverse event path

    Designate a US contact and a clock for required reports.

  5. 5
    Track rules vs reports

    PFAS report (Dec 2025) is an assessment, not a ban. Asbestos method rule was withdrawn Nov 2025. State PFAS laws can still bind you.

Obligation map

Topic SME note Source
Facility listing Register applicable facilities Official
Product listing List marketed cosmetics
Safety substantiation Adequate evidence under labeled conditions of use
Adverse events Serious AE reporting
Federal vs state FDA report is not a state-law shield Official

Common pitfalls

  • Assuming a small brand has no MoCRA duties
  • Listing once and never updating
  • Treating the FDA PFAS report as a federal ingredient ban
  • Ignoring state PFAS/chemical laws (e.g. Illinois Cosmetic Products Act)
  • Mixing drug claims into cosmetic positioning

More context

Use this hub to sequence US work. Listing and adverse-event processes are live duties. Several MoCRA rulemakings (GMP, fragrance allergens, talc/asbestos methods) remain on a delayed or re-proposed path — check FDA.gov, not social recaps.

What this page covers

Federal MoCRA orientation plus pointers to state chemical laws. Confirm exemptions and current rule status on FDA.gov.

Recent regulatory updates

All news

Related Insights

Track updates in Workbench, or upgrade for full Regulatory Details and follow-up tools.

Always confirm requirements against official publications before decisions.

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