MoCRA Compliance Guide for Cosmetics Brands (2026)

By KECC FDA Consulting · Updated April 2026 · 10 min read

The Modernization of Cosmetics Regulation Act (MoCRA), signed into law in December 2022, represents the most significant update to US cosmetics regulation in over 80 years. For cosmetics brands — especially those based in China and Asia — understanding and complying with MoCRA is now essential for continued access to the US market.

      MoCRA applies to you if: You manufacture, process, pack, or hold cosmetic products for distribution in the United States — regardless of where your company is located. This includes Chinese and other foreign manufacturers.
    

Key MoCRA Requirements

Requirement	Who	Deadline / Status
Facility Registration	All cosmetic manufacturers, processors, packers	Required since July 1, 2024
Product Listing	Responsible persons (brand owners)	Required since July 1, 2024
Safety Substantiation	Responsible persons	Required (ongoing)
Labeling Updates	All cosmetic products	Phased implementation
Serious Adverse Event Reporting	Responsible persons	Required since December 2023

Facility Registration

Under MoCRA, every facility that manufactures or processes cosmetic products for distribution in the US must register with the FDA. Registration must be renewed every two years. For foreign facilities, the registration must include the name and contact information of a US Agent.

Registration is done through the FDA's Cosmetics Direct system. Each facility receives a unique Facility Registration Number (FRN) upon registration.

Product Listing

In addition to facility registration, the "responsible person" (typically the brand owner or US importer) must submit a product listing for each cosmetic product marketed in the US. The product listing must include:

Product name and category
List of ingredients (in INCI nomenclature)
Facility where the product is manufactured
Product label (or image of label)

What Happens If You're Not Compliant?

The FDA has authority under MoCRA to take enforcement action against non-compliant facilities and products, including:

Refusal of product admission at US ports of entry
Mandatory recall authority
Suspension of facility registration
Civil monetary penalties

⚠️ Already past the deadline? If your facility has not yet registered and your products have not been listed, you should take action immediately. The FDA has been ramping up enforcement in 2025-2026. KECC FDA can complete your MoCRA registration in 3 business days.

Get MoCRA compliant in 3 days. KECC FDA's complete package is $899.

Start MoCRA Registration