MoCRA compliance: what cosmetic brands must do in 2026
Since the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) was enacted, cosmetic companies that sell in the United States face stronger obligations. Most of its obligations already apply: facility registration, product listing, serious adverse event reports, safety records and a contact on the label. Here is where things stand in October 2026, and which product data you need to keep structured to stay compliant.
What MoCRA requires, and since when
MoCRA was signed into law on December 29, 2022, as part of the Consolidated Appropriations Act, 2023. Most obligations fall on the responsible person: the manufacturer, packer or distributor whose name appears on the label.
| Requirement | What you must do | Date or status (October 2026) |
|---|---|---|
| Facility registration | For facilities in scope, register each facility that manufactures or processes cosmetics for the US market; renew every two years | Due December 29, 2023; enforced since July 1, 2024. New facility: within 60 days |
| Product listing | List each product with its category, ingredients (fragrances, flavors and colors included) and facilities; update every year | Same dates. New product: within 120 days of marketing |
| Serious adverse events | Report them to the FDA with a copy of the label; keep records of all adverse events | Within 15 business days. Records: 6 years (3 for some small businesses) |
| Safety substantiation | Ensure, and keep records supporting, that each product is safe | In force |
| Label contact information | A domestic address, domestic phone number or electronic contact for adverse event reports | Since December 29, 2024 |
| Fragrance allergen labeling | Plan to identify and declare fragrance allergens according to the requirements the FDA will set | Proposed rule due June 29, 2024; still in development |
| Good manufacturing practices | Comply with cosmetic GMP regulations | Proposed rule due December 29, 2024; still in development |
| Asbestos testing for talc | Use standardized testing methods for talc-containing products | Proposed December 27, 2024; withdrawn November 28, 2025 |
The FDA can also access safety records and order a mandatory recall. Certain small businesses are exempt from facility registration, product listing and the future GMP requirements. These exemptions do not apply, however, to some product categories considered higher risk.
Where the pending rules stand
As of October 2026, the FDA has not published its proposed rule on fragrance allergens. The law asks it to consider international requirements, including those of the European Union. Brands that already sell in Europe have information on fragrance allergens, but they will need to check their compliance once the US requirements are defined.
State laws on top of MoCRA
Several states ban cosmetic ingredients that federal law still allows. The ban applies to intentionally added ingredients in any product sold in the state. Here are a few examples of restrictions in California and Washington State:
| State | Ingredients banned | Applies from |
|---|---|---|
| California | Formaldehyde, quaternium-15, mercury, two phthalates, two parabens; all intentionally added PFAS | January 1, 2025 |
| Washington | Ortho-phthalates, PFAS, formaldehyde, methylene glycol, mercury, triclosan, lead | January 1, 2025 |
| California | A second list including lily aldehyde (lilial), cyclotetrasiloxane (D4), styrene, boric acid and borates, several musks | January 1, 2027 |
This table shows only a few examples of restrictions. Requirements can vary by substance and by conditions of use.
The product data you need to keep structured
To meet MoCRA and state requirements, brands need to find the information on their products quickly:
- the formula and its ingredient list, fragrance, flavor and color components included
- the label on the market and the responsible person shown on it
- the safety data of each ingredient, with the supplier documents behind it
- the manufacturing facilities and the history of formula changes
How beCPG keeps this data consistent
In beCPG, each raw material carries its ingredients and their quantities. Formulation calculates the ingredient list of the finished product, and the INCI list excludes ingredients marked as impurities. Each ingredient record holds its legal name, CAS and EINECS numbers, and an FDA code field. Allergens linked to an ingredient roll up to every product that uses it, and product specifications manage allergen thresholds and prohibited ingredients.
The regulatory module checks ingredients by country and by regulatory use, with the status, the restriction level and the exact regulatory citation behind each result. The beCPG regulatory database covers the United States: FDA lists, MoCRA and State laws such as California, Washington or Vermont. See regulatory compliance in beCPG.
Toxicological data is entered per ingredient. Supplier documents live in the document management of the product, formula changes are kept as versions with their history, and the customer complaint module centralizes and tracks complaints. The same data feeds the EU Product Information File.
To meet MoCRA requirements, brands need to find and update the information on the composition, manufacturing and safety of their products. To see how beCPG organizes this information for your range, request a demo.
Frequently asked questions
Who is the responsible person under MoCRA?
The manufacturer, packer or distributor whose name appears on the label. This person lists the products, reports serious adverse events and keeps the safety substantiation records.
Do I have to declare fragrance allergens on US labels today?
Not under MoCRA yet. The law requires it, but the FDA has not published the list of fragrance allergens. As of October 2026, the proposed rule is still in development, so no compliance date is set.
How often must I update my product listings?
Every year. A new product must be listed within 120 days of being marketed, and facility registrations are renewed every two years.
Sources
- FDA, Modernization of Cosmetics Regulation Act of 2022 (MoCRA)
- FDA, Registration and Listing of Cosmetic Product Facilities and Products
- FDA, Talc
- Consolidated Appropriations Act, 2023 (Pub. L. 117-328), Division FF, Title III, Subtitle E
- California Health and Safety Code, section 108980 and section 108981.5
- Revised Code of Washington, RCW 70A.560.020
