Free Tool · MoCRA Rules for 2026–2027

Do I Need MoCRA Registration in 2027?Answer 5 quick questions and get your answer in one minute

Find out whether your cosmetic brand or factory must register with FDA, list products, or qualifies for the small business exemption — and what every brand selling in the U.S. still has to do.

Start the Free Checker → See the Rules
1 min
To Get Your Answer
$1M
Small Business Threshold
$0
FDA Fee

MoCRA Checker

Question 1

MoCRA in 2026–2027: What Applies to Whom

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) gave FDA new powers over cosmetics sold in the United States. Facility registration and product listing have been enforced since July 1, 2024, and the rules continue through 2027.

RequirementWhoHow oftenSmall business exempt?
Facility registrationFactories that manufacture or process cosmetics for the U.S. (foreign ones need a U.S. Agent)Renew every 2 yearsYes, unless higher-risk products
Product listingThe Responsible Person (the brand on the label)Update every yearYes, unless higher-risk products
Label: U.S. contact for adverse eventsEvery cosmetic sold in the U.S.On every labelNo
Serious adverse event reportsThe Responsible PersonWithin 15 business days of learning of oneNo
Safety substantiation recordsThe Responsible PersonKept for each productNo
ℹ️

"Higher-risk" products remove the small business exemption: products that regularly contact the eye area, injected products, products for internal use, and products meant to change appearance for more than 24 hours that the consumer does not remove.

The Small Business Exemption, Simply

If your average yearly U.S. sales of cosmetic products over the last three years are under $1 million, you do not have to register a facility or list products with FDA — as long as you do not make any of the higher-risk products above. The exemption does not cover labeling, adverse event reporting or safety records, so every brand still needs a compliant label.

More detail: Is your cosmetics business exempt from MoCRA?

Our MoCRA Prices

Facility Registration + U.S. Agent

$300 for 1 year or $450 for 2 years. Includes the registration and U.S. Agent service for foreign factories.

Product Listing

$150 per product, filed under the Responsible Person.

Cosmetic Label Review

$250. Ingredient list, net quantity, warnings, claims and the U.S. adverse event contact.

FEI Number Request

$100. The FDA facility identifier needed for registration, if you don't have one.

FDA charges no fee for cosmetic registration or listing.

Related Guides

Frequently Asked Questions

Do I need MoCRA registration in 2027?

If you manufacture or process cosmetics sold in the U.S., your facility must be registered with FDA and the registration renewed every two years. If your name is on the label (the Responsible Person), each product must be listed with FDA and the listing updated every year. These rules continue in 2027. Small businesses with under $1 million in average yearly U.S. cosmetic sales are exempt from registration and listing unless they make certain higher-risk products.

What is the MoCRA small business exemption?

Businesses whose average gross annual U.S. sales of cosmetic products over the previous three years are under $1,000,000 (adjusted for inflation) do not have to register facilities or list products. The exemption does not apply if they make products that regularly contact the eye area, injected products, products for internal use, or products meant to change appearance for more than 24 hours that the consumer does not remove.

If I am exempt, do I still need to do anything?

Yes. Small businesses still need a compliant label, including a U.S. address, phone number or website for adverse event reports, must report serious adverse events to FDA, and must keep records showing their products are safe.

Who is the Responsible Person under MoCRA?

The Responsible Person is the manufacturer, packer or distributor whose name appears on the cosmetic product label. The Responsible Person lists products with FDA, handles adverse event reports and keeps safety records.

Does a foreign cosmetic factory need a U.S. Agent?

Yes. Foreign facilities that manufacture or process cosmetics for the U.S. must name a U.S. Agent when registering with FDA.

Is sunscreen a cosmetic under MoCRA?

Products such as sunscreen, anti-dandruff shampoo and acne treatments are regulated as over-the-counter drugs in the U.S. They follow FDA's drug establishment registration and drug listing rules instead of MoCRA registration.

How much does MoCRA registration cost?

FDA charges no fee. Orionex charges $300 for cosmetic facility registration with one year of U.S. Agent service, or $450 for two years; $150 per product listing; $100 for an FEI number request; and $250 for a cosmetic label review.

Not Sure What Applies to You?

Send us your product list and we will tell you exactly what MoCRA requires — free, within one business day.

Ask Our Team →