/>iAs you know, MoCRA was passed just over two years ago on December 29, 2022, and imposed extensive new requirements related to cosmetic products. We have covered those provisions at length across various alerts, which we have hyperlinked below.
Now that it is officially 2025, we wanted to recap which MoCRA requirements have gone into effect and which are still yet to come. With that in mind, we have compiled below a comprehensive list of MoCRA requirements and their effective dates:
- Exemption for Small Businesses: December 29, 2022
- Exemption for Certain Products and Facilities: December 29, 2022
- Record Keeping Requirements: December 29, 2023
- Safety Substantiation Requirements: December 29, 2023
- FDA Mandatory Recall Authority: December 29, 2023
- Adverse Event Reporting Requirements: December 29, 2023
- FDA Enforcement Authority: December 29, 2023
- Alert available here.
- Professional Use Labeling Requirement: December 29, 2023
- Alert available here.
- General Labeling Requirement: December 29, 2024
- Alert available here.
- Facility Registration Requirements: July 1, 2024
- Product Listing Requirements: July 1, 2024
- Talc-Containing Cosmetic Requirements: To Be Determined
- This requirement will go into effect after the FDA has undergone the rulemaking process and promulgated new regulations. Note that on December 26, 2024, the FDA published a proposed rule regarding these requirements.
- Alerts available here and here.
- Good Manufacturing Practice (GMP) Requirements: To Be Determined
- This requirement will go into effect after the FDA has undergone the rulemaking process and promulgated new regulations.
- Alert available here.
- Fragrance Allergen Labeling: To Be Determined
- This requirement will go into effect after the FDA has undergone the rulemaking process and promulgated new regulations.
- Alert available here.
