Since the adoption of the Modernization of Cosmetics Regulation Act (MoCRA), the regulatory landscape for cosmetics in the United States has evolved significantly.
While initial deadlines were clearly defined, several key regulatory initiatives have since been delayed, revised, or clarified by the FDA.
Understanding where things stand today is essential for companies navigating MoCRA compliance in 2026.
What has already taken effect
MoCRA officially came into force on December 29, 2023, introducing major obligations for cosmetic companies, including:
- Facility registration
- Product listing
- Safety substantiation
- Adverse event reporting
- Recordkeeping requirements
Enforcement of facility registration and product listing began in July 2024, marking the transition from preparation to operational compliance.
Talc testing rule: proposal withdrawn
One of the early regulatory initiatives under MoCRA concerned standardized testing methods for detecting asbestos in talc-containing cosmetic products.
However, on November 28, 2025, the FDA announced the withdrawal of the proposed rule.
This decision reflects the need for further evaluation following industry feedback and indicates that no final rule is expected in the short term.
Fragrance allergens: significant delay
The proposed rule on fragrance allergens has been significantly delayed.
Originally expected in 2024, and later in early 2025, it is now scheduled for May 2026 in the form of a Notice of Proposed Rulemaking (NPRM).
While U.S. requirements are still pending, companies can already rely on the framework currently in place in Europe and Canada, as both regions follow the same list of fragrance allergens and aligned thresholds.
To support companies in identifying and managing these substances, a dedicated resource is available, covering regulated allergens and associated requirements.
👉 Explore our full fragrance allergen resource
GMP requirements: moved to long-term actions
The development of Good Manufacturing Practice (GMP) requirements for cosmetics has also been postponed.
Initially expected in 2025, the GMP rule has now been moved to the FDA’s “Long-Term Actions” list, meaning:
- No NPRM is expected within the next 12 months
- The timeline for implementation remains uncertain
Companies should nevertheless anticipate future GMP alignment and begin structuring internal processes accordingly.
PFAS: report published, but no federal ban
On December 29, 2025, the FDA published its report on PFAS in cosmetic products.
The agency concluded that:
- Current data are insufficient to determine safety
- No federal ban is currently in place
However:
- FDA may take action if safety concerns arise
- Several U.S. states are already implementing restrictions
This creates a fragmented regulatory environment that companies must monitor closely.
What this means for companies in 2026
MoCRA is now entering a second phase.
The focus is no longer on initial registration, but on ongoing compliance management.
Companies should prioritize:
- Maintaining accurate facility and product data
- Monitoring regulatory updates and delays
- Preparing for future requirements (GMP, allergens)
- Managing multi-level compliance (federal + state)
The regulatory framework is still evolving, and companies must remain adaptable.
Key takeaway
MoCRA is not a fixed regulatory framework.
It is a dynamic system, where timelines shift and requirements evolve.
Companies that rely only on initial compliance efforts risk falling behind.
Going further
If you need support navigating MoCRA requirements or managing your regulatory data, our team can assist you.
Since the adoption of the Modernization of Cosmetics Regulation Act (MoCRA), the regulatory landscape for cosmetics in the United States has evolved significantly.
While initial deadlines were clearly defined, several key regulatory initiatives have since been delayed, revised, or clarified by the FDA.
Understanding where things stand today is essential for companies navigating MoCRA compliance in 2026.
What has already taken effect
MoCRA officially came into force on December 29, 2023, introducing major obligations for cosmetic companies, including:
- Facility registration
- Product listing
- Safety substantiation
- Adverse event reporting
- Recordkeeping requirements
Enforcement of facility registration and product listing began in July 2024, marking the transition from preparation to operational compliance.
Talc testing rule: proposal withdrawn
One of the early regulatory initiatives under MoCRA concerned standardized testing methods for detecting asbestos in talc-containing cosmetic products.
However, on November 28, 2025, the FDA announced the withdrawal of the proposed rule.
This decision reflects the need for further evaluation following industry feedback and indicates that no final rule is expected in the short term.
Fragrance allergens: significant delay
The proposed rule on fragrance allergens has been significantly delayed.
Originally expected in 2024, and later in early 2025, it is now scheduled for May 2026 in the form of a Notice of Proposed Rulemaking (NPRM).
While U.S. requirements are still pending, companies can already rely on the framework currently in place in Europe and Canada, as both regions follow the same list of fragrance allergens and aligned thresholds.
To support companies in identifying and managing these substances, a dedicated resource is available, covering regulated allergens and associated requirements.
👉 Explore our full fragrance allergen resource
GMP requirements: moved to long-term actions
The development of Good Manufacturing Practice (GMP) requirements for cosmetics has also been postponed.
Initially expected in 2025, the GMP rule has now been moved to the FDA’s “Long-Term Actions” list, meaning:
- No NPRM is expected within the next 12 months
- The timeline for implementation remains uncertain
Companies should nevertheless anticipate future GMP alignment and begin structuring internal processes accordingly.
PFAS: report published, but no federal ban
On December 29, 2025, the FDA published its report on PFAS in cosmetic products.
The agency concluded that:
- Current data are insufficient to determine safety
- No federal ban is currently in place
However:
- FDA may take action if safety concerns arise
- Several U.S. states are already implementing restrictions
This creates a fragmented regulatory environment that companies must monitor closely.
What this means for companies in 2026
MoCRA is now entering a second phase.
The focus is no longer on initial registration, but on ongoing compliance management.
Companies should prioritize:
- Maintaining accurate facility and product data
- Monitoring regulatory updates and delays
- Preparing for future requirements (GMP, allergens)
- Managing multi-level compliance (federal + state)
The regulatory framework is still evolving, and companies must remain adaptable.
Key takeaway
MoCRA is not a fixed regulatory framework.
It is a dynamic system, where timelines shift and requirements evolve.
Companies that rely only on initial compliance efforts risk falling behind.
Going further
If you need support navigating MoCRA requirements or managing your regulatory data, our team can assist you.
