With these new obligations (registration of establishments and notification of products, reporting of serious undesirable effects, etc.), the Modernization of Cosmetics Regulation Act (MoCRA) is now in place in the United States. However, there are still adjustments to be made and new habits to be integrated. At Cosmetic Valley’s 22nd Congress on Regulatory Issues - Fragrance & Cosmetics, Béatrice Mühl, from Registrar Corp, gave an update on the initial “feedback from the field”.
Registrations of facilities and products listing
Today, all operators must have their facilities registrations and cosmetic product listings completed, the deadline having been extended to 1 July 2024. But this does not mean that everything is finished, as there are still obligations to renew and update.
Facilities registrations
They must be renewed every two years on the basis of the initial registration date, and updated within 60 days of any change. “This obligation to update is quite important, because the facilitie registration includes a lot of data, such as the brands for which you manufacture, the responsible person and all the product categories for each brand and each responsibleperson,” Béatrice Mühl emphasised. “And you have to be careful, because if it’s not updated or if the registration is not active, it blocks the product registrations that are linked to the facilitie.”
Product listings
They have to be renewed every year, along with the updates. “The obligation to renew annually on the anniversary date has not been confirmed in writing, but we have had this confirmation from the FDA several times verbally,” Béatrice Mühl warned, “and this implies fairly complex maintenance insofar as we can add products to the listing, have …
