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MoCRA was the first substantial change to US cosmetics law since 1938. Three and a half years on, this is what it required, what took effect, and what never issued.

The first cosmetics law in eighty years

MoCRA was enacted on 29 December 2022 — 3.6 years ago — and has produced 0 final rules. Of the 9 obligations tracked here, 5 are in force because the statute made them self-executing. Every one that depends on FDA writing a rule is outstanding.

Before MoCRA, the FDA's authority over cosmetics rested on a 1938 statute that gave it no power to require registration, no access to safety records, and no mandatory recall. MoCRA added eleven new sections to the Food, Drug, and Cosmetic Act, listed below. The question this page answers is a narrow and checkable one: what did it require, by when, and what has actually happened.

FD&C §Title
604Definitions
605Adverse events
606Good manufacturing practice
607Registration and product listing
608Safety substantiation
609Labeling
610Records
611Mandatory recall authority
612Small businesses
613Exemption for certain products and facilities
614Preemption

Every deadline on this page is computed from the enactment date and the statute's own “not later than” clauses, read in the enrolled text: Public Law 117-328, Division FF, Title III, Subtitle E — U.S. Congress (congress.gov). FDA's own summary pages are not used as a source for any of them.

Requirement by requirement

RequirementCiteStatutory deadline StatusDetail
Facility registration for facilities operating at enactmentFD&C 607(a)2023-12-29in forceFDA issued a compliance-policy guidance in November 2023 stating it did not intend to enforce registration and listing until 2024-07-01.
Cosmetic product listing for products marketed at enactmentFD&C 607(c)2023-12-29in forceSame November 2023 compliance policy applied.
Serious adverse event reports submitted within 15 business daysFD&C 605(b)(1)2023-12-29in force
Adequate substantiation of safety, with recordsFD&C 6082023-12-29in forceThe statute defines adequate substantiation but sets no test methods and requires no rule, so the standard is in force and undefined in detail.
Label must carry a domestic contact route for adverse event reportsFD&C 609(a)2024-12-29in force
Standardised methods for detecting asbestos in talc-containing cosmeticsMoCRA 35052023-12-29withdrawnProposed rule published 2024-12-27, roughly a year past the statutory deadline, then withdrawn on 2025-11-28 without a final rule. No proposal is currently pending.
Good manufacturing practice regulationsFD&C 6062024-12-29not issuedNo proposed rule has appeared in the Federal Register. The only FDA action on the record is an April 2023 listening session.
Fragrance allergen labelling, and the regulation defining which substances are fragrance allergensFD&C 609(b)2024-06-29not issuedNo proposed rule has appeared in the Federal Register. Because the statute leaves the allergen list to be set by regulation, the labelling duty has no operative content.
Report assessing use and safety of PFAS in cosmeticsMoCRA 35062025-12-29not confirmedA report of this kind is published on FDA's own website rather than in the Federal Register, and fda.gov could not be reached from this machine (TLS interception). Recorded as unverified rather than as missing.

Status is as at 19 August 2026. “Not confirmed” appears once, for the PFAS report, which is published on FDA's own website rather than in the Federal Register — and fda.gov could not be reached from the machine this was built on. It is recorded as unverified rather than as missing, because those are different claims.

What is overdue

RequirementDueStatus Months late
Standardised methods for detecting asbestos in talc-containing cosmetics2023-12-29withdrawn31.7
Fragrance allergen labelling, and the regulation defining which substances are fragrance allergens2024-06-29not issued25.7
Good manufacturing practice regulations2024-12-29not issued19.6

The talc rule, proposed and withdrawn

Proposed rule published 2024-12-27, roughly a year past the statutory deadline, then withdrawn on 2025-11-28 without a final rule. No proposal is currently pending. Talc's asbestos question is the single most concrete ingredient-safety issue MoCRA named, and one product in this corpus declares talc.

Proposed rule, 2024-12-27 · Withdrawal, 2025-11-28

The allergen rule that would have given section 609(b) its content

The statute requires a label to identify each fragrance allergen, but leaves the identity of those allergens to be set by regulation. No proposed rule has issued, so the duty has no list and binds no one. The European Union, over the same period, added 45 substances to its declarable list and let the transition deadline for placing non-compliant products on the market pass on 31 July 2026. Five of the twelve products already declare EU allergens anyway, because global formulas travel with global labels.

The whole Federal Register record

12 documents mentioning MoCRA by name have appeared in the Federal Register since enactment: 0 final rules, 1 proposed rule, and 1 withdrawal — of that same proposed rule. The rest is guidance and administrative notices.

Retrieved 2026-08-19. The single proposed rule is the talc testing proposal, and it is also the single withdrawal. Everything else on the record is guidance or an administrative notice. Source: Federal Register full-text search — Office of the Federal Register.

What this does and does not show. A missed rulemaking deadline is a fact about the rulemaking record, not a judgement about the agency, and guidance documents do real work even though they are not rules — the November 2023 compliance policy is why registration and listing became workable at all. What the record does establish is that the parts of MoCRA that need a rule to mean anything still do not have one.