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◆ Free Tool · US Cosmetics Law

MoCRA Compliance
Self-Check

◆ What It Does

Twelve questions covering the real obligations in the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) — FDA facility registration, product listing, safety substantiation, adverse-event reporting within 15 business days and the small-business exemption. Built from FDA sources, last verified October 2026. A self-assessment aid, not legal advice.

Before You Start

Who Carries
Which Duty?

Under MoCRA, the responsible person is the manufacturer, packer or distributor whose name appears on the product label (FD&C Act §609(a)). Most duties below — product listing, safety substantiation, adverse-event reporting — sit with that name. Facility registration sits with whoever owns or operates the manufacturing facility. When LuxeFormula Labs manufactures for your brand, our partner facility is FDA-registered (FEI 3031525994) and we supply CoA, SDS and INCI documentation with every order — but the label-side duties stay with the brand named on the label. Answer for your brand.

12 questions

Registration, listing, safety, adverse events, labels, GMP, records, exemptions.

15 business days

The deadline to report a serious adverse event to FDA.

Every 2 years

Facility registration renewal cycle; changes updated within 60 days.

Under $1M

Average US sales threshold for the small-business exemption (3-year average).

The 12
Questions

Answer every question — unanswered items are flagged in your results. Nothing you answer is uploaded; scoring runs in your browser.

Get the full checklist by email

Sign up for LuxeFormula Labs Updates and we will email you the full MoCRA checklist — all twelve duties with the FDA source for each, in a printable worksheet. Joining is free, every signup is confirmed by a double opt-in email, and you can unsubscribe at any time.

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Sources

Built on
FDA Sources

Every obligation in this checker traces to the FDA pages below. MoCRA is still being implemented: as of October 2026, FDA has not finalized the fragrance-allergen disclosure rule or the cosmetic GMP rule the statute requires, so those two items are marked “rule pending — prepare now”. Last verified: October 2026.

  1. FDA — Modernization of Cosmetics Regulation Act of 2022 (MoCRA) — facility registration, product listing, safety substantiation, adverse events, pending rulemakings.
  2. FDA — Cosmetics & U.S. Law — responsible-person definition; registration renewal every two years; changes updated within 60 days; annual listing updates.
  3. Cosmetics Direct (direct.fda.gov) — FDA's portal where facility registrations and product listings are actually filed.
Disclaimer. This tool is a self-assessment aid based on FDA's published MoCRA pages as of October 2026. It is not legal advice and does not create an attorney–client relationship. MoCRA implementation is ongoing and requirements can change; verify your position against the FDA sources above and with qualified regulatory counsel before relying on it.
FAQ

MoCRA
Questions

No. MoCRA added registration, listing, record-keeping and reporting duties — it did not create premarket approval for cosmetics (color additives remain the exception). FDA states this on its MoCRA and Cosmetics & U.S. Law pages; registration or listing is never an FDA endorsement of a product.
The manufacturer, packer or distributor whose name appears on the label. If your brand name is on the bottle, that is normally you — even if a contract manufacturer made the product. The manufacturer separately carries the facility-registration duty for its own sites.
Only three things: cosmetic GMP requirements, facility registration and product listing — for businesses whose average gross annual US sales over the previous three years are under $1 million (inflation-adjusted). It never exempts adverse-event record-keeping and reporting, safety substantiation or labeling — and it does not apply at all to eye-area (mucous membrane), injected, internal-use or long-wear appearance-altering products.
Not as of October 2026. MoCRA directs FDA to issue both rules, and both were still pending — so this checker scores them as “prepare now”: keep allergen data from your fragrance supplier and follow current good manufacturing practice, rather than waiting for the final text.
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LuxeFormula Labs Updates

Monthly nail-industry news and regulatory updates — MoCRA, state cosmetic rules, and what they mean for your launch. No spam.

One email a month. Every subscription is confirmed by email (double opt-in) — please check your inbox to confirm. Unsubscribe anytime. Questions: sales@luxeformulalabs.com

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