MoCRA Is Taking Shape: Updated FDA Timelines and What Beauty Brands Must Do Before 2026
- info0940688
- Dec 2, 2025
- 3 min read
Updated: Dec 17, 2025
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is the most significant change to United States cosmetics regulation in eighty years. Over the past two months, the FDA has updated its implementation timelines, and beauty brands need to pay close attention.
Even though several deadlines were extended, the core requirements are still coming. Enforcement expectations are rising, and brands that do not prepare now will face compliance delays and unnecessary operational disruptions.
Key Timeline Updates From FDA
Across recent agency announcements and industry guidance, several timelines are becoming clearer:
• Fragrance allergen labeling: FDA plans to publish the proposed rule in May 2026
• Restrictions on formaldehyde in hair smoothing products: Proposed rule targeted for late 2025
• Cosmetics GMP rule: Still in development but expected to align with global standards
• Facility registration and product listing: Enforcement expectations remain active
Even with extended dates, the direction is unmistakable. Cosmetics oversight is moving much closer to drug level structure.
Where Beauty Brands Face the Greatest Risk
1. Fragrance Allergen Disclosure
The days of simply stating “fragrance” on a label are coming to an end.MoCRA will require identification of specific fragrance allergens that have historically caused consumer reactions.
This shift will affect:
• Packaging
• Ingredient recordkeeping
• Supplier documentation
• Reformulation strategies
2. Hair Smoothing Products Under the Microscope
The FDA has repeatedly warned about formaldehyde-releasing chemicals in straightening treatments. Once the rule is in place, products that contain these ingredients will face direct regulatory restrictions and possible reformulation requirements.
3. GMP Requirements
Although the rule is not finalized, FDA expectations are already evolving. Companies should anticipate increased scrutiny in areas such as:
• Document control
• Supplier qualification
• Complaint handling
• Traceability
• Batch production records
• Stability testing
For many small and emerging brands, this will be the most significant operational shift.
What Cosmetic Companies Must Do Now
1. Conduct a MoCRA Compliance Audit
Evaluate your current readiness across labeling, documentation, supplier records, and adverse event tracking. Identify gaps now rather than during enforcement.
2. Strengthen Supplier Agreements
Brands will need ingredient level transparency, especially for fragrance oils.If a supplier cannot provide allergen data or full documentation, that supplier becomes a compliance risk.
3. Prepare for Label and Packaging Changes
Create a packaging update plan now. Once fragrance allergens and restricted ingredients are finalized, fast changes will be required. Planning ahead protects both budgets and timelines.
4. Build an Internal Compliance Calendar
Track rulemaking updates, draft and final guidance, public meetings, and industry enforcement trends.MoCRA is a multi-year process, and brands need ongoing oversight rather than a single checklist.
5. Educate Your Product and Marketing Teams
Marketing claims, clean beauty language, influencer content, and comparative claims all connect to MoCRA requirements. Your team must understand where the risks are so that claims do not inadvertently cross regulatory lines.
The Bottom Line
MoCRA is reshaping how cosmetic products are regulated in the United States. The most successful brands will not wait for final rules. They will begin implementing process updates now, invest in stronger supplier controls, and prepare for mandatory disclosure requirements that will significantly influence formulation, packaging, and marketing in the years ahead.
SOURCES
FDA MoCRA Implementation Hub
FDA Unified Agenda – Fragrance Allergen Rule
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202410&RIN=0910-AI85
FDA Rulemaking – Formaldehyde in Hair Straighteners (NPRM expected late 2025)
https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202410&RIN=0910-AI79
5. Covington – MoCRA implementation update
Focal Point Research – Updated fragrance allergen timelines
https://focalpointresearch.net/fda/fda-announces-updated-timelines-for-key-cosmetic-regulations/
Beveridge & Diamond – Regulatory priorities affecting cosmetics