Cosmetics registrations come due again under federal oversight

Makers and sellers of skin care in the United States are moving into the first renewal season under the Modernization of Cosmetics Regulation Act, known as MoCRA, and the paperwork is surprising some smaller companies.

Shoppers who favor small-batch balms, oils and salves may notice little at first, though more labels now need tidy federal records behind the counter. That shift follows a law signed in December 2022, the first broad revision of national cosmetics law since 1938. The statute calls on sites that make or handle cosmetics to enroll with the Food and Drug Administration, and it calls on the responsible person for every formula to file that formula with its ingredients. Enrollment and filing both need renewal once every two years, so 2026 brings the first repeat round. The agency issues automatic email notices before each due date, which means a stale contact address is the easiest way to overlook one.

For people who buy from independent makers, the consequence sits mostly out of sight. Online marketplaces and shops more often request evidence of enrollment and filing, and many small labels rely on a contract maker to maintain its own enrollment. A label that believed its production partner had managed all the forms may learn otherwise only when a shop requests documentation.

The statute grants narrower firms a measure of relief. Companies whose average yearly cosmetics sales fell below one million dollars across the prior three years are usually excused from site enrollment and formula filing. The exception stops at goods that contact the eye area, are injected, are intended for internal use, or are meant to alter appearance for longer than 24 hours, and it never lifts the duty to report serious adverse events. A tiny maker offering lip balm plus facial oil might qualify, whereas one offering lash preparations would not.

The broader unresolved matter concerns production standards. MoCRA directed the FDA to complete good manufacturing practice rules for cosmetics by the close of 2025, yet that date went by with no finished rule, and legal observers following the process anticipate a draft first with staged introduction afterward, including extended schedules for smaller firms. In the meantime, the agency looks for facilities to demonstrate reasonable controls even absent a full rulebook.

What to watch next is whether the FDA publishes the proposed manufacturing rule this year, and whether lapsed renewals bring the first visible enforcement actions under its new powers, which include mandatory recalls and suspending a facility registration. Brands that have not reviewed their listings and their manufacturers registrations are wise to do so now.