Voluntary Cosmetic Registration Program (VCRP): The Previous Method of Cosmetic Registration Before MoCRA
Before MoCRA, the VCRP (Voluntary Cosmetic Registration Program) was the voluntary registration program for cosmetic products in the United States, in place since 1972. This program allowed cosmetic manufacturers to register their products and ingredients with the FDA, although it was not mandatory. Learn what the VCRP covered, what it did not cover, and how MoCRA, introduced in January 2022, changed cosmetic regulation in the U.S.
The VCRP before MoCRA:
The VCRP was launched in 1972, before the introduction of MoCRA (Modernization of Cosmetics Regulation Act) in 2022. The VCRP was a voluntary registration program, designed to allow the FDA to track cosmetic products circulating in the United States. However, it is important to note that this program did not cover product approval, but only the registration of cosmetic products and associated ingredients.
What the VCRP covered:
- Registration of cosmetic products: This program allowed manufacturers to register their cosmetic products and ingredients with the FDA, facilitating the tracking of their compliance with applicable laws.
- Registration of establishments: Manufacturers, packagers, and distributors of cosmetics were encouraged to register their establishments to provide the FDA with centralized access to information about the products.
- Cosmetic ingredients: The program covered declarations about the ingredients in cosmetic products (the Cosmetic Product Ingredient Statement (CPIS)).
What the VCRP did not cover:
- Approvals: Unlike other categories of products (such as drugs), the VCRP did not require prior approval of cosmetic products before they were marketed. It was a voluntary tracking system, not mandatory.
- Professional products or samples: The VCRP did not cover products intended solely for professional use or samples (such as those distributed in hotels).
The VCRP was therefore not a regulatory control mechanism, but rather a program that allowed the FDA to have an overview of the cosmetic products sold to consumers. MoCRA, introduced in 2022, strengthened these requirements by introducing the obligation to register products within 120 days of their market introduction and imposing new rules on safety, transparency, and labeling.
The change with MoCRA:
Since the introduction of MoCRA, the registration rules have been significantly strengthened. MoCRA made registration mandatory for all cosmetic products within 120 days of their market introduction, also introducing strict requirements regarding safety testing, labels, and ingredient traceability.
For more information on the changes brought by MoCRA and the new obligations for cosmetic products, check out our detailed article:
> MoCRA - The New US Cosmetics Regulation
How were cosmetic products registered before MoCRA?
Before the implementation of MoCRA, businesses followed a two-step process to register with the VCRP:
- Create a VCRP account with the FDA.
- Submit product and ingredient information via the Cosmetic Product Ingredient Statement (CPIS).
The registration was voluntary and not mandatory, but it was recommended to help prove that products complied with product safety legislation.
Who had to register with the VCRP?
- Manufacturers and distributors of cosmetic products intended for consumers.
- Foreign establishments whose products were exported for sale in the United States.
Products had to be registered once they were commercially distributed in the United States, meaning annual sales greater than $1,000.
For more information, feel free to contact us!
Before MoCRA, the VCRP (Voluntary Cosmetic Registration Program) was the voluntary registration program for cosmetic products in the United States, in place since 1972. This program allowed cosmetic manufacturers to register their products and ingredients with the FDA, although it was not mandatory. Learn what the VCRP covered, what it did not cover, and how MoCRA, introduced in January 2022, changed cosmetic regulation in the U.S.
The VCRP before MoCRA:
The VCRP was launched in 1972, before the introduction of MoCRA (Modernization of Cosmetics Regulation Act) in 2022. The VCRP was a voluntary registration program, designed to allow the FDA to track cosmetic products circulating in the United States. However, it is important to note that this program did not cover product approval, but only the registration of cosmetic products and associated ingredients.
What the VCRP covered:
- Registration of cosmetic products: This program allowed manufacturers to register their cosmetic products and ingredients with the FDA, facilitating the tracking of their compliance with applicable laws.
- Registration of establishments: Manufacturers, packagers, and distributors of cosmetics were encouraged to register their establishments to provide the FDA with centralized access to information about the products.
- Cosmetic ingredients: The program covered declarations about the ingredients in cosmetic products (the Cosmetic Product Ingredient Statement (CPIS)).
What the VCRP did not cover:
- Approvals: Unlike other categories of products (such as drugs), the VCRP did not require prior approval of cosmetic products before they were marketed. It was a voluntary tracking system, not mandatory.
- Professional products or samples: The VCRP did not cover products intended solely for professional use or samples (such as those distributed in hotels).
The VCRP was therefore not a regulatory control mechanism, but rather a program that allowed the FDA to have an overview of the cosmetic products sold to consumers. MoCRA, introduced in 2022, strengthened these requirements by introducing the obligation to register products within 120 days of their market introduction and imposing new rules on safety, transparency, and labeling.
The change with MoCRA:
Since the introduction of MoCRA, the registration rules have been significantly strengthened. MoCRA made registration mandatory for all cosmetic products within 120 days of their market introduction, also introducing strict requirements regarding safety testing, labels, and ingredient traceability.
For more information on the changes brought by MoCRA and the new obligations for cosmetic products, check out our detailed article:
> MoCRA - The New US Cosmetics Regulation
How were cosmetic products registered before MoCRA?
Before the implementation of MoCRA, businesses followed a two-step process to register with the VCRP:
- Create a VCRP account with the FDA.
- Submit product and ingredient information via the Cosmetic Product Ingredient Statement (CPIS).
The registration was voluntary and not mandatory, but it was recommended to help prove that products complied with product safety legislation.
Who had to register with the VCRP?
- Manufacturers and distributors of cosmetic products intended for consumers.
- Foreign establishments whose products were exported for sale in the United States.
Products had to be registered once they were commercially distributed in the United States, meaning annual sales greater than $1,000.
For more information, feel free to contact us!
