Understanding the New MOCRA Cosmetics Labeling Requirements in the U.S.

With the recent implementation of the Modernization of Cosmetics Regulation Act (MOCRA), businesses in the cosmetics industry must be aware of and adhere to the new labeling requirements. This blog post will provide an in-depth look at what these changes entail and how they can affect your business.

What is MOCRA?

The Modernization of Cosmetics Regulation Act (MOCRA) is a landmark legislation aimed at updating and enhancing the regulatory framework for cosmetics in the United States. Enacted in [Year], MOCRA represents a significant shift from the previous guidelines, introducing new requirements for safety, manufacturing practices, and, importantly, labeling.

Key Changes in MOCRA Labeling Requirements

Understanding the changes in labeling requirements under MOCRA is crucial for compliance. Here are the primary updates:

1. Ingredient Disclosure

MOCRA mandates that all cosmetic products must list every ingredient on the product label. This includes:

• Ingredients: Components that have a direct effect on the skin or hair. Other components, including those that contribute to the product’s texture, fragrance, or preservation. Ingredients must be listed in descending order of predominance.

2. Allergen Labeling

Under the new regulations, manufacturers must disclose the presence of any potential allergens. This includes common allergens such as:

• Fragrance allergens
• Certain preservatives
• Plant extracts

The final rule on this topic will be released between July and December of the current year 2024.

3. Responsible Person Contact Information

Labels must now include the manufacturer’s or distributor’s contact information which will also be the Responsible Person of the product introduced in the market. This requirement is intended to facilitate consumer inquiries and as an adverse event contact.

• Company Name
• One of the following: US address, US Telephone number or Electronic contacts like an email address or website link.

To note that a Responsible person can be based abroad and will require a US agent, we have mentioned in an article more information about the roles and tasks of the Responsible Person and US agent.

4. Warnings and Directions for Use

MOCRA requires clear warnings and instructions for use to be included on the label. This is to ensure consumer safety and proper usage of the product.

• Usage Instructions: Clear and concise directions on how to use the product.
• Warnings: Information about potential risks and how to avoid them.

5. Expiration Dates

Although the FDA does not require an expiration date it is the responsibility of the manufacturers to assure the safety of the product therefore it is recommended that the cosmetic products display an expiration date, indicating the period within which the product is safe and effective to use.

Importance of Compliance

Compliance with MOCRA’s labeling requirements is not optional. Non-compliance can result in severe consequences, including:

• Product Recalls: Failure to comply can lead to mandatory product recalls.
• Fines and Penalties: Companies may face significant fines and legal penalties.
• Damage to Reputation: Non-compliance can harm a company’s reputation and consumer trust.

Steps to Ensure Compliance

Ensuring compliance with MOCRA’s labeling requirements involves several steps:

1. Review Existing Labels

Conduct a thorough review of your current product labels to identify any areas that need updating.

2. Ingredient Audit

Perform an audit of all ingredients in your products to ensure they are correctly listed on the label.

3. Update Label Designs

Work with your design team to update your labels to include all required information clearly and accurately.

4. Training and Education

Educate your team about the new requirements to ensure everyone understands the importance of compliance and how to achieve it.

5. Regular Compliance Checks

Implement regular compliance checks to ensure ongoing adherence to MOCRA regulations.

Conclusion

The Modernization of Cosmetics Regulation Act (MOCRA) represents a significant shift in the regulatory landscape for cosmetics in the United States. By understanding and adhering to the new labeling requirements, businesses can ensure compliance, maintain consumer trust, and avoid potential legal issues. Stay ahead of the curve by proactively updating your labels and educating your team about these important changes. Contact Cosmereg for full assistance on labeling requirements.