Why the first MoCRA renewals matter for label readers

Two years is the number that controls this story, because cosmetic facility registrations must be refreshed on that interval and 2026 brings the first round. Congress passed the Modernization of Cosmetics Regulation Act in December 2022, and companies that make or sell skin care are now working through renewal paperwork that has surprised some smaller operations.

That 2022 law was the first broad revision of federal cosmetics law since 1938. It directs sites that manufacture or process cosmetics to register with the Food and Drug Administration, and it directs the responsible person for each cosmetic to file a product listing with ingredients. Renewal is required every two years, so 2026 becomes the first renewal period. The FDA issues automatic email notices before each due date, which means a stale contact address is the usual reason a renewal is missed.

Shoppers who favor independent labels will mostly feel this indirectly. Online marketplaces and retail buyers now more often request proof of registration and listing, and many small labels rely on a contract manufacturer to maintain that manufacturer’s own registration. A label that presumed the contractor had completed all filings can learn otherwise only when a retailer requests documentation.

Smaller firms receive partial relief under the statute. Companies with average yearly gross cosmetics sales under one million dollars across the prior three years are generally excused from facility registration and product listing. The exception does not cover products applied around the eyes, products that are injected, products intended for internal use, or products intended to alter appearance for longer than 24 hours, and it leaves the obligation to report serious adverse events in place. A small company offering only lip balm and face oil can qualify, while a company offering lash products cannot.

The wider unsettled issue concerns production standards. MoCRA instructed the FDA to complete good manufacturing practice regulations for cosmetics by the close of 2025, yet that date passed with no final regulation, and firms monitoring the process anticipate a proposal followed by staged compliance, with extended schedules for small businesses. In the meantime, the agency looks for facilities to maintain reasonable controls even in the absence of a detailed code.

The next signals to track are whether the FDA releases the proposed manufacturing regulation during this year, and whether missed renewals produce the first public enforcement steps under its expanded authority, which covers mandatory recalls and suspension of a facility registration. Labels that have not reviewed their product listings and their manufacturers’ registrations would gain from doing that review promptly.