went into effect December 29 , 2023 .
Adequate Safety Substantiation MoCRA also requires the “ responsible person ” for all cosmetic products to maintain records establishing that product is safe for its intended use as of December 29 , 2023 . MoCRA defines this new requirement as “ tests or studies , research , analyses or other evidence or information ,” that an expert in the field would find adequately substantiates the product ’ s safety .
MoCRA Webinars
This means companies either : ( 1 ) need to undertake safety testing through a reputable contract laboratory for products they manufacture or sell under private label ; or ( 2 ) obtain such safety information from the products ’ contract manufacturer .
Preemption Unlike many federal laws , MoCRA does not preempt state laws that cover the
ingredients and use of cosmetics such as Proposition 65 in California and state bans and limits on ingredients in New York , Illinois and California . While making your company MoCRA- compliant can be time-consuming and expensive , state requirements will likely add to future costs for doing \ business .
Don ’ t wait to get in compliance
While FDA has taken its time implementing rules and guidances for MoCRA , no one wants to be caught without its paperwork and policies in order . Contact regulatory and legal compliance specialists sooner rather than later to ensure your company has met its compliance goals . n
Modernization of Cosmetics Regulation Act of 2022 — Key Terms and Provisions
THE FDA HOSTED A WEBINAR titled Modernization of Cosmetics Regulation Act of 2022 – Key Terms and Provisions in April 2023 . This stakeholder webinar provides an overview of the Modernization of Cosmetics Regulation Act of 2022 . It outlines the requirements mandated by the act and the current steps FDA is taking to implement the requirements , including an update on the Voluntary Cosmetic Reporting Program , and information about a public listening session on good manufacturing practices ( GMPs ). To view the video , search for “ MoCRA webinar ” at fda . gov .
MoCRA and You : Readying Your Company for FDA ’ s New Regulations
ISPA RECENTLY HOSTED THE INFORMATIONAL WEBINAR MoCRA and You : Readying Your Company for FDA ' s New Regulations . Hear from experts at law firm Locke Lord . Click “ Advocacy ” under the Resources tab at experienceispa . com to view the video .
PULSE THANKS THESE AUTHORS FOR THEIR EXPERTISE : David Abramowitz and Sharon Blinkoff , Chairs , FDA Regulatory Group , Locke Lord LLP ; Craig R . Weiss , CEO , Consumer Product Testing Co .; John Bailey Jr . Ph . D ., Independent Advisor for Cosmetics and Colors , EAS Consulting Group
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