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Cosmetics · United States

Sell cosmetics in the United States, MoCRA-ready

Under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), most cosmetics sold in the US need a registered facility, a listed product, safety substantiation records and a compliant label. FDA does not approve cosmetics before sale, so the responsibility sits with the company. We support the route, whether you export to the US or are already there.

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US flag in front of New York brownstones, with unbranded cosmetics, a notebook and documents on a stone surface

Registration and listing in FDA Cosmetics Direct

The US in numbers

A large register, and growing

The FDA register

16,398active cosmetic facility registrationsFDA, 30 June 2026
1.3 mactive cosmetic product listingsFDA, 30 June 2026

What MoCRA asks

Every 2 yearsfacility registration renewalFD&C Act, section 607
Every yearproduct listing updateFD&C Act, section 607

Official sources, checked on 8 November 2026.

Is this for you?

Two starting points, one US route

The rules are the same. What changes is who acts in the US for you.

Your company is outside the US

You need a US presence for your facility

  • Brands from Brazil, Europe or elsewhere register their facility with a US agent
  • Product listing filed by the responsible person on the label
  • We build on your existing EU or Brazil files

Your company is in the US

You are the responsible person

  • Manufacturers, packers and distributors named on the label list the products
  • We prepare safety substantiation and label reviews with your team
  • GMP and procedures prepared for the pending FDA rule

The route

Five steps to sell under MoCRA

MoCRA gap analysis

Step 1 of 5

We check where each product stands against MoCRA.

Every product

Talk to a specialist →

What it includes

  • Cosmetic, drug or both: product status checked
  • Formula reviewed for US restrictions and color additives
  • Claims checked for drug claims
  • Clear list of what is missing
Safety substantiation

Step 2 of 5

Records that show each product is safe as used.

Required records · Section 608

Talk to a specialist →

What it includes

  • Ingredient safety data and exposure
  • Tests and studies you already have, reused
  • Gaps and how to close them
  • File organized for FDA records requests
US label

Step 3 of 5

A label that meets FDA rules and MoCRA additions.

On every pack · FPLA and MoCRA

Talk to a specialist →

What it includes

  • Statement of identity and net quantity in US units
  • Ingredient declaration in the right order
  • Name and place of business
  • Domestic address, phone or electronic contact for adverse event reports
Registration and listing

Step 4 of 5

Facility registered, products listed, US agent in place.

Cosmetics Direct · Section 607

Talk to a specialist →

What it includes

  • Facility registration and renewal every 2 years
  • US agent for foreign facilities
  • Product listing with ingredients and yearly update
  • Updates when products or facilities change
GMP and procedures

Step 5 of 5

Procedures prepared while the FDA GMP rule is pending.

Rule pending · Section 606

Talk to a specialist →

What it includes

  • GMP manual written or updated
  • Standard operating procedures for key processes
  • Records and batch documentation
  • Review against the final rule once published

What changes and when

MoCRA milestones, done and pending

  • MoCRA signed into law, the most significant expansion of FDA's authority over cosmetics since 1938MoCRA
  • End of FDA's enforcement grace period for facility registration and product listingFDA
  • Labels must carry a domestic contact for adverse event reportsFD&C Act, section 609
  • FDA publishes its report on PFAS in cosmeticsFDA
  • Final guidance on mandatory cosmetic recallsFDA
  • Cosmetic GMP final ruleFD&C Act, section 606
  • Fragrance allergen labeling ruleFD&C Act, section 609
  • New proposal on asbestos testing in talc productsFDA

Dates checked on 8 November 2026. We confirm the current status in every project.

Coming from the EU or Brazil?

What you can reuse, and what the US needs

You already have

  • Formula and INCI list
  • Supplier safety data
  • Stability and challenge tests
  • EU safety report (CPSR) as safety evidence
  • GMP evidence (ISO 22716)

You need for the US

  • Safety substantiation file for the US
  • US label in English with US units
  • Facility registration and US agent
  • Product listing in Cosmetics Direct

See the EU route →

Why Sobel

Regulation as a business decision, not a checklist.

Four disciplines work on every project, in the same team, from the first decision to post-market.

Strategy

Classification and market sequence decided first. The right class from day one avoids rework.

Science in house

Biological, clinical and toxicological evaluation by our own Clinical Evidence & Product Safety team.

Regulatory, five markets

ANVISA, FDA, EU MDR, MHRA and Health Canada, coordinated together.

Technology

A dedicated technology team builds the workflows that keep every project traceable and on time.

“We know how auditors think, because we’ve been one of them.”

Maik Endler

Founder & CEO

  • Mechanical engineer, trained in Germany
  • Former BSI auditor (Notified Body)
  • Industry experience at Sirona (now Dentsply Sirona)

Questions, answered

Frequently asked questions

Rules cited on this page: Modernization of Cosmetics Regulation Act of 2022 (MoCRA) · Federal Food, Drug, and Cosmetic Act, Chapter VI · Fair Packaging and Labeling Act · 21 CFR Parts 700–740

What is MoCRA?

The Modernization of Cosmetics Regulation Act of 2022, signed on 29 December 2022. It is the most significant expansion of FDA's authority over cosmetics since 1938 and added facility registration, product listing, safety substantiation, adverse event reporting, labeling changes, GMP rules and mandatory recall authority.

Do I need to register my cosmetics with the FDA?

Facilities that manufacture or process cosmetics for the US market register with FDA and renew every two years. The responsible person lists each product, with its ingredients, and updates the listing every year. Both are filed in FDA Cosmetics Direct. Some small businesses are exempt, but not for products such as eye-area, injected, internal-use or long-wear products.

Does the FDA approve cosmetics before they are sold?

No. Apart from color additives, cosmetics do not need FDA approval before sale. Under MoCRA, the responsible person must keep records that adequately substantiate the safety of each product.

Does a foreign company need a US agent?

Yes, for facility registration. A foreign facility that registers with FDA must name a US agent. The product listing is filed by the responsible person whose name appears on the label.

What must a US cosmetic label show?

In English: the identity of the product, the net quantity, the ingredient list, the name and place of business and the required warnings. Since MoCRA, the label must also give a domestic address, phone number or electronic contact for adverse event reports.

Who is the responsible person under MoCRA?

The manufacturer, packer or distributor whose name appears on the label. The responsible person lists the products, keeps the safety substantiation and handles the obligations linked to each product.

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