FDA Cosmetic & MoCRA Regulatory Compliance
FDA Cosmetic Facility Registration & MoCRA Compliance Services
FDA Cosmetic Facility Registration is the mandatory federal filing in which every domestic and foreign establishment that manufactures or processes cosmetics for U.S. commercial distribution submits its facility, owner/operator, and product information to the U.S. Food and Drug Administration. The requirement is established under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), enforced through Section 607 of the Federal Food, Drug, and Cosmetic Act and the FDA's official MoCRA program via the Cosmetics Direct portal. Registration identifies your facility to the FDA, links it to a Responsible Person, and enables submission of every cosmetic product you market in the United States. Without a current registration, your cosmetics are considered adulterated or misbranded under the FD&C Act — exposing your shipments to Import Alert detention, FDA Warning Letters, product seizure, and removal from Amazon, Walmart, and other retail platforms.
- Who Must Register
- All domestic and foreign facilities that manufacture or process cosmetics for U.S. distribution — manufacturers, contract manufacturers, repackers, and private-label producers.
- Governing Regulation
- Modernization of Cosmetics Regulation Act of 2022 (MoCRA); FD&C Act §607; 21 U.S.C. §364a.
- Submission System
- FDA Cosmetics Direct electronic portal — Form FDA 5066 (facility registration) and Form FDA 5067 (product listing).
- Key Requirement
- Valid DUNS number tied to the physical facility address; foreign facilities must designate a U.S. Agent with a physical U.S. address.
- Confirmation Issued
- FDA Establishment Registration Number and Cosmetic Product Listing Number, typically returned within 24–48 hours.
- Renewal Cycle
- Annual renewal between October 1 and December 31; product listings updated yearly or within 60 days of any material change.
- Edge-Case Requirement
- Foreign facilities require a designated U.S. Agent; California sellers with ≥ $1M in annual sales must also file under CSCAR.
- Service Fee
- Flat professional service fee with $0 in government filing charges — the FDA does not charge a fee for MoCRA facility registration.
Expert FDA cosmetic facility registration, product listing, U.S. Agent services, labeling compliance, and annual renewal for domestic and foreign cosmetic companies selling in the U.S. market.
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Complete FDA Cosmetics & MoCRA Compliance Services
Navigating FDA cosmetic regulations under MoCRA is complex, time-consuming, and costly if done incorrectly. Whether you are a domestic manufacturer, foreign cosmetic brand, or contract manufacturer, compliance with the U.S. Food and Drug Administration is mandatory before distributing cosmetics in the United States.
MoCRA Facility Registration
Register your domestic or foreign cosmetic facility with the FDA under the Modernization of Cosmetics Regulation Act.
Get started →MoCRA Product Listing
List all cosmetic products you manufacture or process for the U.S. market using FDA Form 5067.
Get started →U.S. Agent Services for Cosmetic Facilities
Foreign cosmetic facilities must designate a U.S. Agent — we serve as your FDA-authorized U.S. Agent for MoCRA compliance.
Get started →Cosmetic Labeling & Ingredient Review
Ensure your cosmetic labels meet FDA MoCRA requirements — ingredient declarations, warnings, and net contents reviewed by specialists.
Get started →California Safe Cosmetics Act (CSCAR)
Report cosmetic ingredients linked to cancer or reproductive harm to the California Safe Cosmetics Program.
Get started →DUNS Number Assistance for Cosmetics
Obtain the DUNS number required to complete your FDA cosmetic facility registration.
Get started →MoCRA Listing Certificate
Receive an official MoCRA Listing Certificate as proof of your FDA cosmetic facility registration and product listing status.
Get started →MoCRA Annual Renewals
Keep your FDA cosmetic facility registration current — we track your renewal deadline and handle the full annual renewal submission.
Get started →Ready to Get Your Cosmetic Facility MoCRA Registered?
Join 1,000+ cosmetic companies across 135 countries who trust FDA Registration Assistance for fast, accurate, and fully compliant FDA cosmetic facility registrations completed in as little as 24–48 hours.
Do You Need Registration?
Who Is Required to Register a Cosmetic Establishment?
Under 21 CFR Part 701 / MoCRA, a wide range of cosmetic businesses are legally required to register their establishments with the FDA — regardless of company size or country of origin.
Why FDA Registration Assistance
The Trusted Choice for FDA Cosmetic Compliance
⚡ Fast 24–48 Hour Turnaround
Most cosmetic facility registrations and product listings are completed within 24 to 48 hours.
✅ 100% Accurate Filings
Our expert team ensures every product listing, registration, and labeling submission is complete and error-free.
🌍 135+ Countries Served
We work with cosmetic companies across 135+ countries entering the U.S. market.
🔒 No Government Fees
A simple flat fee handles every step of your FDA cosmetic facility registration and MoCRA compliance.
📅 Renewal Tracking Included
We track your annual renewal deadlines so your registration is never deactivated.
📞 Dedicated Regulatory Support
A dedicated regulatory expert is assigned to your account for inspection support and import alert resolution.
🏆 15+ Years Experience
For 15+ years we have guided over 1,000 cosmetic companies through FDA registration and compliance.
🚀 End-to-End Compliance
From registration through product listing, U.S. Agent services, labeling, and annual renewal — all in one place.
Compliance Coverage
FDA Cosmetic Regulations We Handle
All cosmetics manufactured, distributed, or imported into the U.S. fall under FDA jurisdiction. Our team covers every regulation that affects your cosmetic business.
Simple Process
How Our FDA Cosmetics Compliance Process Works
Getting your cosmetic establishment registered with the FDA is straightforward when handled by experts. Here is our proven 4-step process.
Complete our short intake form with facility details, product categories, responsible person, and contact information.
Our regulatory experts review your submission, confirm categories, identify FDA codes, and prepare your filings.
We submit your registration and product listings directly to FDA via Cosmetics Direct. Confirmed within 24–48 hours.
You receive your FDA Establishment Registration Number. We monitor renewal deadlines and provide ongoing support.
Legal Authority
The Federal Laws Behind MoCRA Cosmetic Registration
FDA cosmetic facility registration is grounded in three layers of U.S. federal law — the founding statute, the operational regulations, and the modernization act that turned voluntary registration into a mandatory program.
Federal Food, Drug, and Cosmetic Act (1938)
Enacted by Congress in 1938, the FD&C Act (21 U.S.C. §§ 301 et seq.) is the foundational federal law granting the FDA authority over cosmetics sold in U.S. commerce. It defines what constitutes a "cosmetic," prohibits adulterated or misbranded products, and authorizes the FDA to inspect facilities and stop non-compliant shipments at the border.
View FD&C Act on FDA.gov →21 CFR Part 701 — Cosmetic Labeling
Title 21 of the Code of Federal Regulations, Part 701, operationalizes the FD&C Act's cosmetic provisions. It dictates label format, required statements (identity, net quantity, manufacturer/distributor name and address), and full INCI ingredient declaration in descending order of predominance.
View 21 CFR Part 701 on eCFR →Modernization of Cosmetics Regulation Act (MoCRA) 2022
Signed into law on December 29, 2022 as part of the Consolidated Appropriations Act, MoCRA is the most significant expansion of FDA cosmetic authority in over 80 years. It made facility registration and product listing mandatory, introduced the Responsible Person concept, required Serious Adverse Event reporting, and gave the FDA mandatory recall authority over cosmetics.
View MoCRA on FDA.gov →MoCRA Responsibilities
Core Responsibilities of a MoCRA-Compliant Cosmetic Facility
Under MoCRA and the FD&C Act, every registered cosmetic facility and Responsible Person carries a defined set of legal duties.
Role Comparison
U.S. Agent vs. MoCRA Responsible Person
These two MoCRA roles are constantly confused — but they are legally distinct, and most cosmetic businesses need both.
| Attribute | U.S. Agent | MoCRA Responsible Person |
|---|---|---|
| Who Designates It | The foreign cosmetic facility designates the U.S. Agent during FDA facility registration. | The brand owner whose name appears on the cosmetic label is automatically the Responsible Person. |
| Who It Represents | Represents the foreign cosmetic facility to the FDA for communications and inspections. | Represents the cosmetic product itself — accountable for its safety, labeling, and FDA listing. |
| Required By | Required only for foreign cosmetic facilities registering under MoCRA. | Required for every cosmetic product marketed in the U.S., regardless of origin. |
| Governing Regulation | MoCRA §607; FD&C Act §704; FDA Cosmetics Direct portal requirements. | MoCRA §§ 605–608 (SAERs, listing, safety substantiation, recall authority). |
| Primary Function | Accept FDA correspondence; coordinate facility inspections; act as domestic point of contact. | Submit product listings; maintain safety substantiation; report SAERs; respond to recall orders. |
| Required For | Foreign manufacturers, contract manufacturers, processors exporting cosmetics to the U.S. | All brand owners, importers of record, private-label sellers of cosmetics in the U.S. |
The U.S. Agent and the MoCRA Responsible Person are two separate roles that cannot be substituted for each other. A foreign cosmetic manufacturer almost always needs both: a U.S. Agent to interface with the FDA on behalf of the foreign facility, and a Responsible Person — typically the brand owner — to legally stand behind each individual cosmetic product. FDA Registration Assistance routinely provides both services as a coordinated package.
Self-Filing vs. FDA Registration Assistance
MoCRA registration is technically open to any business — but the FDA's Cosmetics Direct portal, DUNS validation, INCI mapping, and U.S. Agent linking are unforgiving of errors.
| Factor | DIY Self-Filing | Recommended — FDA Registration Assistance |
|---|---|---|
| Cost | $0 government fee, but high opportunity cost in staff hours, missed deadlines, and rework. | Flat professional service fee, no hidden charges, no government filing fee added. |
| Availability | Limited to your internal team's working hours and learning curve; portal navigation can take weeks. | Dedicated regulatory specialist; submissions typically completed in 24–48 hours. |
| MoCRA Expertise | You research MoCRA, Cosmetics Direct, INCI requirements, and product code mapping on your own. | Specialists with 15+ years of FDA cosmetic experience across 1,000+ filings and 135+ countries. |
| Risk of Filing Failure | High — wrong DUNS, mismatched codes, incomplete INCI, or missing U.S. Agent links cause rejections. | Pre-submission QA on every field; 100% accurate-filing track record. |
| Confirmation Handling | You monitor the Cosmetics Direct portal yourself for Registration Number and listing IDs. | We deliver your FDA Establishment Registration Number and product listing numbers with written compliance confirmation. |
| Renewal Tracking | You manually track the Oct 1 – Dec 31 renewal window and 60-day product update obligations. | Automatic renewal alerts and proactive filing every October–December. |
Most cosmetic brands choose a dedicated MoCRA service because the cost of a single mistake — a delayed shipment, an Import Alert, or a missed renewal — vastly exceeds the cost of professional filing.
Friend-as-U.S.-Agent vs. Professional U.S. Agent
A common foreign-brand shortcut is asking a friend, relative, or U.S.-based contact to serve as the designated U.S. Agent.
| Factor | Friend / Informal U.S. Contact | Recommended — FDA Registration Assistance U.S. Agent |
|---|---|---|
| Government Fee | $0 — the FDA does not charge a fee to designate a U.S. Agent. | $0 government fee; flat annual professional service fee covers monitoring, response, and recordkeeping. |
| Pros | No external service cost; trusted personal relationship. | FDA-monitored mailbox, 24–48 hour response SLA, written confirmation of every FDA communication, professional liability coverage. |
| Cons | Missed or ignored FDA emails, no inspection expertise, no liability, no audit trail — single missed notice can trigger Import Alert. | Annual fee — offset by avoiding even one detained shipment (typical cost: $10,000+). |
| Best For | No legitimate use case for a commercial cosmetic business. | Any foreign cosmetic facility actively shipping to the U.S. market under MoCRA. |
The "free" friend-as-agent option carries the highest hidden cost. A single missed inspection notice or recall request can put your entire product line on Import Alert overnight. A professional U.S. Agent is the small annual fee that prevents that catastrophic outcome.
Glossary
MoCRA & FDA Cosmetic Compliance Terms You Should Know
Plain-English definitions for the technical terms you'll encounter during FDA cosmetic facility registration.
The Modernization of Cosmetics Regulation Act of 2022 — the federal law that made FDA cosmetic facility registration and product listing mandatory for the first time.
The FDA's electronic submission portal for filing cosmetic facility registrations (Form 5066) and product listings (Form 5067) under MoCRA.
Under MoCRA, the manufacturer, packer, or distributor named on the cosmetic label who is legally accountable for the product's safety, listing, and adverse event reporting.
A person or entity with a physical U.S. address designated by a foreign cosmetic facility to act as the FDA's domestic point of contact.
A 9-digit Data Universal Numbering System identifier from Dun & Bradstreet required by the FDA to validate a cosmetic facility's physical address.
International Nomenclature of Cosmetic Ingredients — the standardized naming system the FDA requires on cosmetic labels in descending order of predominance.
The unique FDA-issued number assigned to each registered cosmetic facility after successful submission through Cosmetics Direct.
The FDA-assigned number returned for each individual cosmetic product after the Responsible Person submits Form 5067.
The mandatory report a Responsible Person must submit to FDA within 15 business days of learning about a serious adverse event.
Legal terms under the FD&C Act describing cosmetics that fail safety, labeling, or registration requirements.
FDA Detention Without Physical Examination — an automatic hold on all shipments from a non-compliant cosmetic facility at every U.S. port of entry.
The current Good Manufacturing Practices the FDA expects of cosmetic facilities — now backed by MoCRA enforcement.
Common Failures
Why MoCRA Registrations & Cosmetic Shipments Get Rejected
Most FDA cosmetic enforcement actions trace back to the same handful of avoidable mistakes.
Missing or Mismatched DUNS Number
Cosmetics Direct rejects any submission whose DUNS doesn't match the physical address on file with Dun & Bradstreet — the #1 cause of rejection.
Missed Annual Renewal Window
Registrations lapse if not renewed between Oct 1 and Dec 31. Every shipment then becomes importable as "from an unregistered facility."
Unresponsive or Invalid U.S. Agent
FDA correspondence to a friend or out-of-date agent that goes unanswered triggers the same enforcement as having no agent at all.
Non-INCI Ingredient Names on Labels
Listing ingredients by common name ("Vitamin E") instead of INCI ("Tocopherol") makes the product misbranded under 21 CFR Part 701.
Unapproved Drug Claims
Claims like "treats acne" or "prevents wrinkles" reclassify the product as a drug — and cosmetics making drug claims are misbranded.
No Safety Substantiation File
MoCRA §608 requires every Responsible Person to maintain documented safety evidence. No file = Warning Letter.
Failure to Report Serious Adverse Events
Missing the 15-business-day SAER deadline under MoCRA §605 is one of FDA's top inspection findings post-MoCRA.
Relying on Old VCRP Registration
VCRP was terminated March 27, 2023. Companies still pointing to VCRP as proof of filing are non-compliant under MoCRA.
Frequently Asked Questions
FDA Cosmetics & MoCRA Compliance Common Questions
Yes. Under MoCRA, any domestic or foreign facility that manufactures or processes cosmetics for U.S. commercial distribution must register with the FDA. This applies regardless of company size or country of origin.
A mandatory MoCRA requirement for any facility manufacturing or processing cosmetics sold in the U.S. Registration identifies your site in the FDA database and must be updated annually between October 1 and December 31.
Yes. All foreign cosmetic facilities registered with the FDA must designate a U.S. Agent as the official FDA point of contact for communications, inspections, and correspondence.
The process of registering each cosmetic product you market in the U.S. with the FDA via Cosmetics Direct. Every registered facility must list all cosmetic products it manufactures or distributes.
Under MoCRA, all cosmetics sold in the U.S. must meet FDA requirements for facility registration, product listing, labeling, and safety substantiation. Products making drug claims are regulated as both.
Yes. A DUNS number is required to complete FDA cosmetic facility registration through Cosmetics Direct. Without a valid DUNS, registration cannot be processed.
Your cosmetic shipments will be automatically detained at U.S. ports of entry. To resolve, identify the root cause and submit corrective documentation to FDA.
CSCA requires cosmetic manufacturers, packers, and distributors with annual California sales of $1M+ to report any product containing an ingredient listed as a potential carcinogen or reproductive toxicant.
Annually between October 1 and December 31. Failure to renew on time results in a lapsed registration.
Your products may be considered adulterated or misbranded under the FD&C Act, resulting in import refusals, FDA enforcement, warning letters, product seizure, or recall.
Yes, but regulatory mistakes are common and costly. Professional assistance reduces risk, improves submission quality, and accelerates market entry.
Typically 24–48 hours when the application is complete and accurate. Delays usually result from missing DUNS or incomplete owner/operator information.
No. Unlike drugs or devices, cosmetics do not require FDA premarket approval. However, MoCRA requires all facilities to register and all products to be listed.
Under MoCRA, manufacturers must submit Serious Adverse Event Reports to FDA within 15 business days. Records must be retained for 6 years.
Yes. We review cosmetic labels, ingredient lists, and promotional materials to ensure they meet FDA labeling requirements under 21 CFR Part 701.
Facility registration confirmation, product listing records, MoCRA documentation, complaint files, labeling files, safety substantiation data, SAERs, and inspection records.
Yes, if they comply with FDA facility registration, product listing, and MoCRA requirements before entering U.S. commerce.
FDA inspectors review facility registration, product listings, manufacturing processes, ingredient documentation, safety substantiation, and adverse event records.
Yes. Selling cosmetics online does not exempt a company from FDA requirements. Any establishment manufacturing, repackaging, relabeling, or importing must register.
Facility legal name and address, DUNS number, owner/operator info, U.S. Agent details, type of establishment activity, and a product list with categories and INCI ingredients.
Documented evidence that a cosmetic product is safe for its intended use — ingredient safety assessments, toxicological data, stability testing, and clinical or consumer safety data.
Yes. We track your annual renewal deadlines, handle required updates, and ensure your compliance is maintained year-round.
Labels must comply with 21 CFR Part 701: product identity, net quantity, manufacturer/packer/distributor name and address, and full INCI ingredient declaration in descending order.
Yes. We perform a root-cause review of the Import Alert, prepare response documentation, and submit corrective action evidence to the FDA.
The manufacturer, packer, or distributor whose name appears on the cosmetic product label. Legally accountable for safety, listing, and SAER reporting.
End-to-end support — from registration and listing through labeling, U.S. Agent services, import alert resolution, and annual renewals.
A flat professional fee with $0 in government filing charges — the FDA does not charge a fee for MoCRA facility registration. The service fee includes intake review, DUNS verification, facility data preparation, U.S. Agent linking review, Cosmetics Direct submission, written confirmation of your FDA Establishment Registration Number, and a downloadable compliance certificate. Most clients bundle MoCRA Product Listing alongside facility registration in the same 24–48 hour window.
Technically yes, but strongly discouraged. The FDA requires only a physical U.S. address reachable during business hours. However, a friend or relative who misses an FDA email, ignores an inspection notice, or fails to respond on time can cause your registration to be flagged, your shipments placed on Import Alert, and your products detained. A professional U.S. Agent is monitored every business day, trained in FDA correspondence, and accountable through a written service agreement.
The FDA treats it as if you never responded. Consequences include placement on Import Alert (automatic Detention Without Physical Examination), suspension of facility registration, refusal of entry, Warning Letters, and civil penalties. Many brands first learn about a missed notice when a container is stopped at the port.
Update the registration in Cosmetics Direct with the new agent's information, and the new agent must confirm acceptance to the FDA. We handle the full switchover: preparing the updated record, coordinating acceptance from the new agent, submitting through Cosmetics Direct, and providing written confirmation. Most changes complete within 24–48 business hours. No FDA fee.
It depends. True soap (alkali + fats, marketed only for cleansing) is regulated by CPSC, not FDA. Soap making cosmetic claims IS a cosmetic and requires MoCRA. Candles are generally not cosmetics. Perfumes, fragrances, body sprays, and colognes ARE cosmetics and require full MoCRA registration and product listing.
Yes. The sales channel does not change the requirement. Amazon and Walmart Marketplace actively request proof of MoCRA registration and will delist non-compliant products. Shopify and Etsy do not pre-screen, but selling cosmetics without registration violates the FD&C Act.
In most cases yes. Manufacturers with average gross annual U.S. cosmetic sales under $1,000,000 over the previous three years are exempt — unless they manufacture higher-risk products such as injectables, products contacting eye mucus membranes, products for internal use, or products altering appearance for more than 24 hours.
Not publicly. The FDA does not publish a public search tool for MoCRA registrations. Verification is done internally by FDA and CBP at the port of entry. Request a copy of the FDA Establishment Registration Number and product listing numbers from your supplier.
Yes — both, in different roles. Every facility that physically manufactures or processes a cosmetic must register. Separately, the Responsible Person (brand owner whose name appears on the label) must submit the product listing.
The facility address must be the physical location where cosmetics are actually manufactured — no P.O. Boxes or pure virtual offices. A home-based manufacturer may register the home address if real production occurs there. The U.S. Agent address must also be a physical U.S. address.
No, and claiming so is illegal. MoCRA registration is an administrative compliance step — it does NOT constitute FDA approval. Marketing a cosmetic as 'FDA approved' or displaying the FDA logo is a misbranding violation. Use 'FDA registered' or 'MoCRA compliant' instead.
The FDA recognizes only two categories: cosmetics and drugs. There is no FDA classification called 'cosmeceutical' — the term has no legal meaning. Products making BOTH cosmetic and drug claims (sunscreens, antiperspirants, anti-dandruff shampoos, acne treatments) are regulated as BOTH.
Within hours, when registration is correct. CBP and FDA verify status electronically at the port. Compliant shipments typically clear within hours. Non-compliant shipments are flagged for Detention Without Physical Examination, adding days to weeks of delay.
VCRP is dead — MoCRA replaced it. The Voluntary Cosmetic Registration Program was officially terminated on March 27, 2023. VCRP registrations do NOT carry over to MoCRA — every cosmetic facility must file a fresh MoCRA registration in Cosmetics Direct.
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Reviewed by Hector Matos, Senior Regulatory Compliance Specialist · Last reviewed July 2026
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