The short answer
Salon hair color, developers, perm and relaxer solutions, keratin treatments, professional skin peels and back-bar shampoos are cosmetics (unless they make drug claims), so the MoCRA basics apply: facility registration, product listing, safety records and serious adverse event reporting.
MoCRA added one label rule just for them. A cosmetic intended to be used only by professionals must carry a clear and prominent statement that it shall be administered or used only by licensed professionals, and it must still meet the other federal labeling requirements (21 U.S.C. 364e(c)).
Who counts as a “professional”?
MoCRA defines a professional as an individual licensed by an official State authority to practice cosmetology, nail care, barbering or esthetics. Salons and their staff are licensed by states, not by FDA. FDA regulates the products.
Label checklist for professional-use products
| Label element | Professional-only product | Same product sold at retail or online |
|---|---|---|
| “Use only by licensed professionals” statement | Required — clear and prominent | Not meant for retail; if it is sold to consumers, it is a consumer product too |
| Product identity, net quantity, name and place of business | Required | Required |
| U.S. contact for adverse event reports | Required | Required |
| Ingredient list in descending order | FDA’s ingredient labeling rule applies to products sold at retail; many brands still include it | Required |
| Warnings and directions (for example the coal-tar hair dye caution) | Required where they apply | Required where they apply |
Product types to watch
- Hair dyes and color: coal-tar hair dyes need the FDA caution statement and patch test directions. See hair dye requirements.
- Keratin and hair smoothing treatments: FDA has raised concerns about smoothing products that release formaldehyde when heated. Your safety records and directions must address this.
- Professional peels and microneedling products: claims about removing scars, treating acne or “stimulating collagen” can be drug claims; needling tools can be devices.
- Back-bar sizes: large refill containers for salons are still listed products and still need the professional statement if they are professional-only.
MoCRA steps for a professional brand
- 1Register the factoryWith a U.S. Agent if it is outside the U.S. Renew every 2 years.
- 2List each productIncluding professional-only products. Update listings every year.
- 3Fix the labelAdd the licensed-professionals statement and the U.S. adverse event contact; decide whether the product will ever be sold at retail.
- 4Keep safety recordsBased on how professionals use the product — exposure time, heat, mixing with developers.
- 5Set up adverse event handlingSalons report reactions to the brand; serious ones go to FDA within 15 business days. See adverse event reporting.
Example: a professional hair color brand from Italy
An Italian brand sells permanent hair color, developer and a bond-repair treatment to U.S. salons through distributors. It registers its factory under MoCRA with a U.S. Agent, lists every shade and the developer, and adds “For use only by licensed professionals” prominently to each tube and bottle, along with the coal-tar caution statement and a U.S. contact. Because the bond-repair treatment will also be sold online to consumers, that product gets a full retail label with an ingredient list.
Cosmetic facility registration with U.S. Agent from $300 (1 year) or $450 (2 years). Product listing $150 per product. Cosmetics label review $250.
Frequently asked questions
What must a professional-use cosmetic label say?
A clear and prominent statement that the product shall be administered or used only by licensed professionals, plus the other federal labeling elements such as identity, net quantity, the responsible company and a U.S. adverse event contact.
Do salon-only products need MoCRA product listing?
Yes, unless a small business exemption applies. Professional-only products are still cosmetics.
Do salon-only products need an ingredient list?
FDA’s ingredient labeling rule applies to products sold at retail to consumers. If a professional product is also sold to consumers, including online, it needs one.
Who is a licensed professional under MoCRA?
An individual licensed by a state to practice cosmetology, nail care, barbering or esthetics.
Sources
- 21 U.S.C. 364e — Cosmetic labeling (professional use, adverse event contact)
- Loeb & Loeb — MoCRA increases FDA oversight of the cosmetics industry
- Arnall Golden Gregory — FDA modernizes cosmetic product labeling requirements
Requirements checked on November 11, 2026. This article is general information, not legal advice.