Cosmetic manufacturers that registered with the Food and Drug Administration when the agency's new facility-registration system opened are now hitting their first renewal deadlines, due every two years from each facility's original registration date, according to the FDA's own guidance on the Modernization of Cosmetics Regulation Act (MoCRA). A facility that registered on February 20, 2024, for example, owes its renewal by February 20, 2026, the agency says.
MoCRA, signed into law in December 2022, gave the FDA authority it had not held over cosmetics in 84 years, according to an FDA statement on the law's implementation. Before MoCRA, the agency had no mandatory registry of who was making cosmetics sold in the United States or what those products contained. The law changed that by requiring most facilities that manufacture or process cosmetics for the U.S. market to register with the FDA using a facility identifier number, and requiring the "responsible person" behind each product, typically the brand, to list every marketed cosmetic and its ingredients with the agency, per the FDA's registration and listing guidance.
Why is 2026 the year this catches up with brands?
The original compliance date for registration and listing was December 29, 2023, but the FDA pushed enforcement back six months to July 1, 2024, to give the industry more time to comply, the agency said in a compliance policy notice announcing the delay. That grace period meant most first-wave registrations landed in mid-2024, which is why a large share of renewal deadlines are now falling in 2026 rather than 2025. The FDA's guidance walks brands through renewal using the same channels as initial registration: the Cosmetics Direct portal, the ESG NextGen system, or SPL Xforms, with paper forms 5066 and 5067 available but discouraged.
How much of the industry has actually registered?
As of June 30, 2026, the FDA counted 16,398 active facility registrations and 1,298,361 active product listings in its system, according to the agency's registration and listing page. Both figures apply to any entity that manufactures, packs, or distributes cosmetic products in the U.S., though the FDA carves out an exemption for small businesses, except when those businesses make products that contact the eye area, are injected, are meant for internal use, or claim to alter appearance for more than 24 hours without removal, per the same guidance. Products already regulated as drugs or medical devices fall under separate rules and exemptions.
What else did MoCRA change beyond paperwork?
The registration system is only part of the law. MoCRA also requires companies to keep records substantiating the safety of their cosmetic products, a documentation requirement that did not exist before the law, according to the FDA's implementation statement. The agency said reports of adverse events tied to cosmetics, submissions from consumers, healthcare providers, and companies about reactions or injuries linked to a product, have more than tripled since the law took effect, a jump the FDA attributes largely to reporting that used to be entirely voluntary. To handle the increase, the agency launched a new Adverse Event Monitoring System, described in its own statement as a single public-facing dashboard consolidating those reports. For brands and the retailers that carry them, the renewal deadline is a compliance checkbox; the adverse-event and safety-substantiation requirements are the parts of MoCRA that actually change what a company has to be able to prove.
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