MoCRA 2026: The Grace Period Is Over.
If your brand hasn't begun to comply, you might be in trouble.
Let me be direct (as if I’m not always direct 😉), if your brand is still treating MoCRA like the distant rumble of a regulatory thunderstorm, you’re about to get soaked in an unexpected downpour.
On February 11, 2026, the FDA updated its Cosmetics Direct portal with new features for facility registration renewals, including real-time registration status displays and renewal date fields. The agency also refreshed its guidance page, user guide, and supporting instructions.
PAT ATTENTION!
This wasn’t just some website rearranging and housekeeping. It was the agency making compliance as visible and trackable as possible, and that should tell you something about where enforcement is headed.
MoCRA (the Modernization of Cosmetics Regulation Act of 2022) is the most significant change to U.S. cosmetics regulation since 1938. For eighty-four years, the industry operated under a framework so minimal that facility registration was voluntary and ingredient disclosure was largely optional.
How voluntary?
When the FDA published its first MoCRA compliance data in March 2025, the numbers were striking: 9,528 active facility registrations and 589,762 unique product listings under the new mandatory system. That’s nearly double the facility registrations and more than sixteen times the product listings compared to the old Voluntary Cosmetic Registration Program. That gap represents an entire industry that simply chose not to show up when nobody was taking attendance.
The Renewal Cycle Is Already Beginning
Facility registration was required by July 1, 2024, with biennial renewals. That means the first wave of renewal deadlines is arriving, NOW. If you registered your facility in February 2024, your renewal is already due this month. If you made the July deadline, you’ve got until mid-2026, but that’s going to arrive faster than your planning calendar suggests.
I’m not sure why so many brands have been dragging their feet. The FDA has made the process straightforward.
Cosmetics Direct now displays registration status and renewal date fields on every facility’s homepage, and the agency is sending email reminders. But brands don’t seem to understand that the consequences of falling behind are real. Products from unregistered or improperly listed facilities are legally considered misbranded or adulterated, which means border holds, import seizures, and the kind of disruption that makes retail partners rethink their relationship with a brand. MoCRA also grants the FDA authority to suspend facility registrations entirely when products pose serious adverse health risks, effectively shutting down a facility’s ability to distribute cosmetics in the United States.
Where the Actual Rulemaking Stands
While registration and listing are fully in effect, several of MoCRA’s more complex provisions remain in various stages of rulemaking. The timelines have shifted repeatedly, and I know some of you have been looking at the delays and thinking you’ve been handed more breathing room. You have. But confusing a delay with a reprieve is a mistake you’re only going to want to make once.
Fragrance allergen labeling is targeted for a proposed rule in May 2026. The original statutory deadline was June 2024, so this has been pushed back significantly. The FDA is expected to identify specific substances as fragrance allergens requiring label disclosure, with strong alignment to EU requirements. From a practical standpoint, brands should already be requesting allergen statements and IFRA certificates from their fragrance suppliers. A final rule likely won’t land before 2027, but the companies that have already mapped their fragrance compositions against the EU’s existing allergen lists will have a meaningful head start when the proposed rule arrives. The ones that haven’t will be redesigning packaging under deadline pressure, which is exactly as expensive and chaotic as it sounds.
The proposed formaldehyde restriction for hair-smoothing and straightening products is where this story becomes genuinely difficult to tell with professional detachment. The FDA has now missed its target date for this proposed ban six times: October 2023, April 2024, November 2024, March 2025, July 2025, and December 31, 2025. As of January 2026, the agency has stated only that the rule remains “a priority” without providing a new timeline. Formaldehyde is a well-established carcinogen that also causes respiratory irritation and skin sensitization, and the people bearing the greatest burden of these delays are salon workers and Black women, who disproportionately use these treatments and who have been advocating for regulatory action since 2021.
Six missed deadlines aren’t a scheduling problem. It’s a failure of urgency, and people are being harmed while the agency adjusts its calendar.
Talc and asbestos testing appears to be the rulemaking most likely to stay on schedule. The proposed rule requiring standardized detection methods was published in December 2024, with a final rule targeted for March 2026.
Good Manufacturing Practices (GMP) have been moved to the Unified Agenda’s “long-term actions” list, which is the regulatory equivalent of “we’ll get back to you.” The statutory deadline for even proposing GMP regulations was December 29, 2024, and that deadline passed without action. No new target date has been set. But here’s what matters: the absence of a formal GMP rule does not create a compliance vacuum. The FD&C Act’s existing adulteration provisions remain fully enforceable, and FDA inspections continue. ISO 22716, the international standard the agency has repeatedly signaled it will reference, provides a clear framework for any facility serious about operating at a professional level.
The Political Landscape
MoCRA was enacted with bipartisan support in December 2022, and its core provisions remain in full force under the current administration. Early enforcement data from 2025 showed the FDA issuing warning letters under MoCRA at a pace consistent with the prior administration, and the current administration has not taken steps to alter registration, listing, or adverse event reporting requirements.
That said, the broader regulatory environment has shifted. Executive Order 14192 introduced a “one-in, ten-out” requirement, mandating that agencies repeal 10 existing regulations for every new regulation finalized. The FDA has also undergone leadership changes at both the agency and the Office of Cosmetics and Colors, as well as staffing reductions. These factors explain why MoCRA’s more complex rulemakings keep missing deadlines. The requirements already on the books are being enforced, but the rules that would provide the industry with clearer guidance on GMP, allergens, and ingredient restrictions continue to be pushed back.
It leaves the industry in a frustrating position - expected to comply with regulations of a law whose rules haven’t been fully written.
What Brands Should Be Doing Now
Companies that move early during regulatory transitions don’t just survive them; they set the standard everyone else has to meet.
So, here’s what current compliance with MoCRA looks like in practical terms:
Confirm your registration and renewal status immediately.
Log in to Cosmetics Direct, check the new status and renewal date fields, and put your deadline on every calendar that matters. If you registered in early 2024, you may already be due.
Build or audit your adverse event reporting system. MoCRA requires serious adverse event reports submitted to the FDA within 15 business days.
Begin fragrance allergen mapping now by requesting full allergen data from your fragrance suppliers.
Cross-reference against the EU’s existing disclosure requirements. When the FDA’s proposed rule lands, it will be tighter than anyone expects, so following the strictness of existing EU rules will keep your brand safe.
Operate to GMP standards regardless of the rule’s status. The current ISO 22716 covers production, personnel, documentation, and quality controls. Implementing it now protects you during inspections and positions you well ahead of whatever the final rule requires.
Develop safety substantiation files for every product you market. MoCRA requires it, and even though the FDA hasn’t defined what adequate substantiation looks like or provided samples, the standards will likely be established in light of enforcement actions. You do not want to be the brand they use as an “example” of what NOT to do.
#MyTwoCents
MoCRA’s implementation has been slower and messier than the statute intended. For example, the delays around formaldehyde are particularly hard to justify given the human cost. But the direction is unmistakable: the grace period is OVER, the era of cosmetics operating as the most loosely regulated consumer product category in the US is ending.
The brands that will come through this FDA restructuring strongest are the ones paying attention to how MoCRA evolves, building real compliance infrastructure, and treating regulation as a competitive advantage rather than an inconvenience.
I can state with confidence that companies that don’t take MoCRA seriously at this point will become examples of “what not to do” and face substantial fines and potential shutdowns.