It is two years old, but the implementation of the Modernization of Cosmetics Regulation Act (MoCRA), the regulatory framework for cosmetics in the United States, has not yet reached full maturity. Some rules are still missing, while the implications of those already in effect can be measured. At the 23rd Cosmetic Valley Regulatory Issues - Fragrances & Cosmetics Congress held on November 19 and 20, 2025, Béatrice Mühl of Registrar Corp provided an update on the latest developments.
To be fully effective, the MoCRA still lacks implementing regulations. These were expected by 2025, but will be published with additional delays.
The rules to come… or not
GMPs
The FDA was already behind schedule and had finally set a target date of late 2025 for proposing regulations. The schedule has been revised and the date is now “to be determined.”
“Clearly, this means that it is not a priority for the FDA in the various regulations that remain to be published under MoCRA,” Béatrice Mühl explained. “However, don’t think that it won’t happen. There is every reason to believe that, on the contrary, it will happen, since the publication announcing the postponement specified the future location of the regulation in the Code of Federal Regulations, which will be part 711 of CFR 21.”
But with a date “to be determined,” it is unlikely that much will happen in 2026 and that we will see any changes in the FDA’s current inspection policy.
Allergens
The FDA must establish a list of allergens, with a view to possibly making their labeling mandatory, initially expected by the end of 2025. The Administration has announced a proposed regulation for …
