- Cosmetics facility registrations need renewal on a two year cycle, with 2026 as the first test.
- The FDA manufacturing practice rule missed its late 2025 target and remains unfinished.
- Very small sellers get limited relief, yet serious safety reports remain mandatory for all.
Brands that make or sell skin care in the United States are entering the first renewal season under the Modernization of Cosmetics Regulation Act, known as MoCRA, and the paperwork is catching some smaller companies off guard at the sink.
Federal cosmetics law went largely unchanged from 1938 until MoCRA was signed in December 2022. That law requires any facility that manufactures or processes cosmetics to register with the Food and Drug Administration, while the responsible person for each product must list the product with its ingredients. Registrations carry a two year renewal cycle, so 2026 brings the first round. The FDA issues automatic email reminders before each due date, which means an old contact address often explains a missed filing.
People who wash with bars, oils and creams from independent labels will notice the impact away from the sink. Online marketplaces and stores now ask makers more often for proof of registration and listing, and many small labels rely on a contract manufacturer to maintain its own registration. A founder who believed the manufacturer covered all filings can learn otherwise only when a retailer requests evidence.
The statute offers partial relief for lower volume companies. Firms with average gross yearly cosmetics sales under one million dollars across the prior three years are usually excused from facility registration and product listing. The carve out falls away for products used around the eyes, products that are injected, products intended for internal use, or products that alter appearance for longer than 24 hours, and it never removes the duty to report serious adverse events. A tiny maker with a lip balm and a face oil can qualify, while a similar maker with lash products cannot.
The wider uncertainty concerns production standards. MoCRA directed the FDA to complete good manufacturing practice rules for cosmetics by the end of 2025, yet the date passed with no final rule, and firms following the process expect a proposal first with later phase in dates, plus extended time for small businesses. In the meantime the agency looks for reasonable controls at facilities even though a detailed rulebook is absent.
What to watch next is whether the FDA publishes the proposed manufacturing rule this year, and whether renewal lapses lead to the first visible enforcement actions under its new powers, which include mandatory recalls and suspending a facility’s registration. Brands that have not checked their listings and their manufacturers registrations are better off doing so now before the next wash day routine.
Ellen Sloane
Ellen looks after the brands Body of Work works with and makes sure every sponsored page says so. She spent years in salon education for a professional hair care company, so she can tell a demonstration from a claim.
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