US FDA Cosmetic Regulation Overhaul (MOCRA)

Within the Consolidated Appropriations Act, 2023 that was passed by the US Congress on December 29, 2022, under Subtitle E, it included the "Modernization of Cosmetics Regulation Act of 2022" (MoCRA), which creates new legal requirements for cosmetic companies and new authority for the US FDA. This Act is expected to provide greater FDA oversight and tracking of cosmetics. Key points in brief: (Definitions: "responsible person" = manufacturer, packer, or distributor of a cosmetic product whose name appears on the label; "facility" = site of manufacturing or processing but not including entities involved solely in one or more of: labeling, packaging, holding, distributing). Facility Registration (Sec. 607(b)): each facility that manufacturers or processes cosmetics for sale in the US, including foreign facilities, must register with the Secretary within 1 year of enactment (by Dec. 29, 2023) and renewed every other year (biennially). Foreign entities must have a US agent on [...]

May 9, 2023|

California Cleaning Product Right to Know Act (Part 1) Now in Effect – Are you Ready?

If your company manufactures any type of cleaning product and sells it into California, then you likely have already heard about the "California Cleaning Product Right to Know Act of 2017" ("the Act"). If not, here is a general summary to bring you up to speed! This Act requires manufacturers of certain types of cleaning products to disclose the presence of certain chemicals on the company's website, as well as on product labels. The website disclosure part of the Act is effective now for products sold on or after January 1st, 2020. The product label disclosure part of the Act becomes effective next year on January 1st, 2021. Essentially, companies need to check whether the ingredients in their products are listed on any of the 22 "designated lists" prescribed in the Act (state, federal, and international chemical databases). This Act applies to "designated products", including (see Act for full definitions): Air care [...]

March 21, 2019|
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