Lexology November 9, 2023
Baker McKenzie

In brief

For quick background, under MoCRA, every person that, on December 29, 2022, owns or operates a facility that engages in the manufacturing or processing of a cosmetic product for distribution in the United States must register each facility no later than December 29, 2023. Further, the responsible person of a cosmetic product that is marketed on December 29, 2022, must submit a cosmetic product listing not later than December 29, 2023. As of today, the FDA is not currently accepting facility registration or product listing submissions. This has led to widespread speculation that the compliance timeline may experience delays. On November 8, 2023, FDA issued a new guidance titled “Compliance Policy for Cosmetic Product Facility Registration and Cosmetic...

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