MoCRA, 10 steps to efficiently manage cosmetics compliance and safety in practice in the US

The Modernization of Cosmetics Regulation Act (MoCRA) is here to stay. Not all requirements are fully defined yet, but you need to prepare to ensure your cosmetic products will be compliant under each new requirements once it become effective.

The best approach to avoid rushing from one deadline to another is to understand the requirements; AND to take 10 key steps to manage product information and to assess and monitor product compliance and safety.

Jasper ten Brinke
By Jasper ten Brinke
Business Development

MoCRA and how to avoid cosmetic products to become non-compliant in 2024?

The Modernization of Cosmetics Regulation Act of 2022(MoCRA) was signed into law on December 29, 2022. The first deadlines are on December 29, 2023. At the same time, the deadlines to comply with individual requirements vary a lot, not all requirements have been exactly defined yet, and the enforcement of the requirements of facility registration and product listing has been postponed with 6 months until July 1, 2024, while the registration system Cosmetics Direct has been launched only very recently on December 18, 2023. Next to MoCRA several “key” states (e.g. California, NewYork) have additional state requirements and continue to do so.

We continuously monitor the evolving requirements under MoCRA and their timelines. The overview table includes the deadline postponement of facility registrations and product listings as communicated by the FDA on November 8, 2023.

MoCRA overview requirements and timelines by TRC

From an "ad-hoc" approach to a "system" approach in 10 steps

So, instead of rushing from one regulatory deadline to another and troubleshooting individual requirements on an “ad-hoc” basis, become more effective and efficient by following our practical and comprehensive 10 key steps approach. Choose for this proven effective approach to best manage cosmetics compliance and safety in practice under MoCRA and state level regulations.

5 key steps to manage product information

Cosmetics compliance management - linking and managing specificationsCosmetics compliance management - structured bottom-up approach

5 key steps to assess and continuously monitor compliance and safety

Live dashboard with cosmetic product portfolio compliance status overview for the USA.

How does following these key principles help you to meet the MoCRA requirements in practice?

Instead of meeting individual requirements on a more “ad-hoc” basis, it is much more efficient and future proof to follow these key steps.  Following these 10 steps results in the output that is needed to meet the MoCRA requirements. To give you some examples for each MoCRA requirement:

Conclusion / Insight

Carefully following these 10 key steps puts you in control, and exactly where you want to be to meet the MoCRA requirements. It is a “system” approach as opposed to a more “ad-hoc” approach, and results in efficiently and effectively meeting current and future MoCRA  and additional state requirements.

Published: December 2023