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What You Need to Know About MoCRA Compliance Deadlines

Published November 12, 2023
Published November 12, 2023
Joshua Sukoff via Unsplash

As we waited for implementation updates as the December 29 deadline loomed, the U.S. Food and Drug Administration (FDA) issued guidance and a constituent update on its intent to delay enforcement of the requirements for cosmetic product facility registration and cosmetic product listing requirements under MoCRA for six months.

Signed and passed into legislation, MoCRA grants the U.S. Food and Drug Administration (FDA) greater control over standards and regulations of the cosmetics industry. The first significant amendment to the FDA’s cosmetics authority since President Franklin Delano Roosevelt signed the Federal Food, Drug, and Cosmetic Act (FFDCA) into law in 1938, this overhaul will ripple throughout the cosmetic supply chain and apply to all cosmetics marketed in the US, including those imported from other countries.

What deadlines have been extended?

The FDA Guidance Documents extend the deadlines for submitting facility registrations and product listings from December 29, 2023, to July 1, 2024. The organization said it will be ready to accept submissions by December 29, 2023, but needs to detail when its electronic database or paper forms will be available for public use.

What deadlines have NOT been extended?

The FDA Guidance limits the extension only to the submission of facility registrations and product listings. The following statutory deadlines under MoCRA have not changed

  • December 29, 2023—Possession of documentation meeting the requirements for adequate safety substantiation and record-keeping requirements for notice of adverse events and requirements for submission of severe adverse event reports
  • June 29, 2024—Inclusion of contact information for a responsible person and identification of fragrance allergens for labeling information on all products 
  • December 29, 2025—Compliance with current good manufacturing practices (CGMPs)

As we continue to wait for implementation updates, speculation and misinformation about the law and the associated requirements have been circulating in the industry, creating confusion for brands and manufacturers. Watch our recent webinar on demand, where we tackle the most common questions.


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