At the 26th Cosmed Regulatory Congress in early April 2026, Marie Magnan and Catherine Apolinario, both international regulatory affairs managers, presented an overview of cosmetic inspections and controls conducted around the world. Here is a summary of the first part of their presentation, covering the United States, Canada, and Brazil.
United States
Since MoCRA came into force, several new requirements have been introduced: for example, all manufacturing facilities must now be registered, and cosmetic products must be subject to a “product listing” (the equivalent of a notification) with the FDA.
This provides the US agency with a wealth of information on companies and products on the market, including foreign establishments exporting to the United States (whereas it had virtually none previously), and, as of 31 March 2025, the FDA had recorded 10,820 registered establishments and 681,831 listed products. A lot of information that it is not doing much with at the moment, agreed Catherine Apolinario.
Mandatory recalls
Another new power granted to the FDA is the ability to order product recalls, which, prior to MoCRA, were initiated solely by companies.
In December 2025, the Agency published a Q&A guide to clarify the conditions and procedures for such recalls, including the classification of the risk levels that may trigger them:
• Class I: serious risk or death
• Class II: temporary or reversible risk
• Class III: low or unlikely risk
Customs checks
A new system has been developed: the FDA ImportShield Program (FISP), which aims to centralise …
