Cosmetics Industry Regulatory Challenges Accelerate

The past three years have marked the most significant expansion of cosmetic industry oversight since 1938. The updates below outline key provisions of the Modernization of Cosmetics Regulation Act of 2022 ("MoCRA") and proliferating state bans, many of which are effective in 2026.

FDA Implements MoCRA: Expanding Oversight Across the Cosmetics Supply Chain

The U.S. Food and Drug Administration ("FDA") continues to implement the Modernization of Cosmetics Regulation Act of 2022 ("MoCRA"), enacted under the Consolidated Appropriations Act of 2023. MoCRA establishes new requirements for the cosmetics sector, including mandatory facility registration, product listing, safety substantiation, and adverse event reporting.