ARTICLE
28 February 2024

FDA Issues Guidance On Cosmetic Facility Registration

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Greenberg Traurig, LLP

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Greenberg Traurig, LLP has more than 2750 attorneys in 48 locations in the United States, Europe and the Middle East, Latin America, and Asia. The firm is a 2024 BTI “Leading Edge Law Firm” for delivering on client expectations for the future and is consistently among the top firms on the Am Law Global 100 and NLJ 500. Greenberg Traurig is Mansfield Rule Certified Plus by The Diversity Lab. The firm is recognized for powering its U.S. offices with 100% renewable energy as certified by the Center for Resource Solutions Green-e® Energy program and is a member of the U.S. EPA’s Green Power Partnership Program. The firm is known for its philanthropic giving, innovation, diversity, and pro bono. Web: www.gtlaw.com.
The Food and Drug Administration (FDA) issued new guidance in January 2024 on facility registration requirements under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA).
United States Food, Drugs, Healthcare, Life Sciences

The Food and Drug Administration (FDA) issued new guidance in January 2024 on facility registration requirements under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). Under MoCRA, cosmetic manufacturers and processors must register their facilities with the FDA and renew the registration every two years. If any such facility fails to register, that facility may not distribute or sell cosmetic products in the United States. Although MoCRA is now in effect, the FDA announced it does not intend to enforce the facility registration and cosmetic product listing requirements until July 1, 2024.

To help facilities decide whether they need to register with the FDA, the FDA published a decision tool which walks through a series of yes/no questions that will determine whether registration with the FDA is required.

Additionally, the FDA announced a set of facility registration and cosmetic product listing tools for cosmetic firms to use in electronically registering and listing products with the FDA. Alternatively, the FDA published two paper forms for FDA cosmetic facility registration and cosmetic product listing. The electronic tools and paper forms are available at the FDA's website.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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