MoCRA Explained: What the U.S. Cosmetics Law Changes Mean for Hair Products and Salons

Quick answer (as of September 17, 2026)

  • The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) gave the FDA its biggest new powers over cosmetics, including shampoos, conditioners, hair dyes, relaxers and styling products, since 1938.
  • In effect now: facility registration, product listing, serious adverse event reporting (within 15 business days), safety substantiation records, FDA records access and mandatory recall authority.
  • Delayed: the required Good Manufacturing Practice (GMP) rule (now a "long-term action") and the fragrance allergen labeling rule (not yet proposed).
  • Withdrawn: the FDA's proposed asbestos testing rule for talc was withdrawn on November 28, 2025, with a revised version promised but not scheduled publicly.
  • Most salons that only use products on clients don't register, but salons that make or relabel products for sale may have obligations.

This is general information, not legal advice. Compliance depends on your specific business; consult a regulatory attorney or consultant.

What MoCRA is

Before MoCRA, U.S. cosmetics companies didn't have to register with the FDA, list products, or report injuries. MoCRA, signed into law in December 2022, changed that. The FDA's own summary lists the core duties: manufacturers and processors must register facilities and renew every two years; a "responsible person" (usually the brand owner) must list each product and its ingredients and update annually; and responsible persons must report serious adverse events within 15 business days (FDA MoCRA page, updated Aug. 10, 2026).

For hair, "cosmetics" covers shampoo, conditioner, color, bleach, perms, relaxers, smoothing treatments, gels and sprays. Products that claim to treat disease or regrow hair (for example, minoxidil) are regulated as drugs, and anti-dandruff shampoos are OTC drugs, under separate rules.

Status tracker: what's in effect, delayed, or withdrawn

Provision Status (Sept. 2026) Confidence
Facility registration & product listing In effect; FDA began enforcement July 1, 2024. As of Jan. 6, 2026, FDA reported 14,299 active facility registrations and 992,907 active product listings (Foley & Lardner, Mar. 2026) High
Serious adverse event reporting In effect (15 business days). FDA launched a public cosmetics adverse event dashboard on Sept. 12, 2025 (Foley) High
Safety substantiation records In effect; no specific test method required, and animal testing is not required (FDA) High
Mandatory recall & records access In effect; FDA issued draft recall guidance Dec. 18, 2025 and draft records access guidance in early 2026 (Crowell & Moring, Apr. 8, 2026) High
GMP regulation Delayed. Statutory deadline for a proposal (Dec. 29, 2024) missed; moved to FDA's "long-term actions" list, meaning no proposal expected within 12 months (Marie Gale; EcoMundo, June 4, 2026) High
Fragrance allergen labeling Not yet proposed. Statutory deadline (June 29, 2024) missed. Agenda target was May 2026; a July 2026 industry report cites November 2026 (Certified Cosmetics) Medium (date unverified on Reginfo.gov)
Asbestos testing for talc products Withdrawn Nov. 28, 2025 after a Dec. 2024 proposal; FDA said it would reexamine and reissue (Federal Register) High
PFAS report to Congress Published Dec. 29, 2025; FDA found data insufficient to determine safety for most PFAS in cosmetics (FDA; Crowell) High

Separate from MoCRA: the FDA's proposed ban on formaldehyde in hair smoothing products is its own rulemaking and, as of September 2026, still hasn't been published.

What MoCRA means for hair brands (including indie and small makers)

  1. Register your facility if you manufacture or process cosmetics for U.S. distribution, and renew every two years.
  2. List every product with its ingredients (including fragrance and flavor ingredients as required), and update annually.
  3. Put a U.S. contact on the label (a domestic address, phone number or electronic contact) so consumers can report adverse events.
  4. Keep safety substantiation records showing your product is safe under normal use.
  5. Report serious adverse events to FDA within 15 business days and keep adverse event records (FDA guidance describes a six-year retention period for most products).
  6. Label professional products correctly. MoCRA requires products intended only for licensed professionals to say so clearly on the label. Check FDA's current labeling guidance for the exact wording.

The small business exemption, and its hair-product catch

MoCRA exempts certain small businesses (generally those with under $1 million in average annual U.S. cosmetics sales) from registration, listing and future GMP rules. But the exemption does not apply to some higher-risk categories, including products intended to alter appearance for more than 24 hours where removal isn't part of normal use. Based on the statute's categories, that likely captures many permanent hair dyes, perms and relaxers. Small color or texture brands should get a professional compliance review rather than assume they are exempt. (Confidence: medium; we could not re-verify the FDA's exemption guidance text during this research session.)

What MoCRA means for salons

Most salons are not "facilities" under MoCRA. The law's registration duty is aimed at manufacturers and processors; FDA guidance generally exempts beauty shops and salons that don't manufacture or process products for sale to consumers outside the salon. However:

  • If you mix, fill, relabel or sell your own private-label products, you may be a manufacturer, processor or responsible person. Get advice.
  • Serious reactions in your chair matter. If a client has a serious reaction (for example, a severe dye allergy needing hospital care), tell the product's manufacturer, whose contact must be on the label, and consider an FDA MedWatch report.
  • Use professional products as labeled. "For professional use only" labels exist for a reason, and they are now a federal labeling requirement.
  • Keep records: product, batch/lot number, and what was applied. It helps clients and any investigation.

What MoCRA means for consumers

  • You can search FDA's public adverse event dashboard for cosmetics.
  • You can report reactions yourself to FDA, and the brand's label contact information makes it easier to report to the company.
  • MoCRA does not require pre-market approval of cosmetics, and FDA still cannot approve most ingredients in advance (color additives are the exception).
  • Fragrance allergen labeling, which would help people with fragrance allergies avoid problem products, isn't in place yet.

How MoCRA interacts with state laws

MoCRA prevents states from adding their own requirements for things like registration, listing, GMPs, recalls and adverse event reporting that differ from federal rules. But state laws banning or restricting specific ingredients, such as California's, Maryland's and Washington's toxic-free cosmetics laws, continue to apply (Foley; Washington Ecology). For hair businesses selling nationally, state ingredient lists are often the stricter standard. (Confidence on the exact preemption scope: medium; consult counsel.)

Compliance checklist

Brands

  • Facility registration current (2-year renewal)
  • Every SKU listed; listing updated annually
  • Label: U.S. contact for adverse events; professional-use statement where applicable
  • Safety substantiation file for each product
  • Adverse event intake, 15-business-day serious report process, record retention
  • State ingredient compliance (CA, MD, WA and others)
  • Voluntary GMP program aligned to FDA's draft guidance/ISO 22716 while the rule is pending

Salons

  • Confirm you don't manufacture/relabel for retail (or get advice if you do)
  • SDSs and labels kept for all back-bar chemicals
  • Reaction log and a plan to report serious events
  • Staff trained to use professional-only products as directed

What we don't know yet

  • When the GMP rule will be proposed; FDA has given no date.
  • Whether the fragrance allergen proposal will appear in late 2026 and which allergens it will list.
  • When a revised talc asbestos-testing rule will be issued.
  • How aggressively FDA will use recall and records-access powers; early enforcement has been limited, with a GMP-related warning letter in November 2025 cited by law firms.

FAQ

Does my salon need to register with the FDA under MoCRA? Usually not, if you only use and retail products made by others. If you manufacture, fill or private-label products, check whether you're a manufacturer or responsible person.

Has the FDA finalized MoCRA's GMP rule? No. As of September 2026, it hasn't even been proposed and sits on FDA's long-term action list.

Will hair products have to list fragrance allergens? MoCRA requires it, but the FDA has not yet proposed the rule. Some brands already disclose allergens voluntarily or for EU sales.

Does MoCRA ban any hair ingredients? Not directly. Ingredient bans come from separate FDA rulemaking (like the pending formaldehyde proposal) and state laws.

Where can I report a bad reaction to a hair product? To the manufacturer (label contact) and to the FDA through MedWatch.

Sources