Modernization of Cosmetics Regulation Act of 2022 (FD&C Act section 609)
For cosmetics brands selling in the US working out what MoCRA added to labels, and what is still to come. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
MoCRA's cosmetics labeling rules, added to the FD&C Act by the Modernization of Cosmetics Regulation Act of 2022, put an adverse event contact and, for salon products, a professional-use statement on labels, with fragrance allergens to follow.1,2
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the label items MoCRA's cosmetics labeling rules describe, according to the Act and FDA, and where each is described as applying.1,2,3
| Requirement | Where it applies |
|---|---|
| Adverse event contact details | A domestic address, phone number or electronic contact, such as a website, for adverse event reports. |
| Professional-use products | A clear and prominent statement that only licensed professionals administer or use the product. |
| Professional-use products: other label information | The same label information the Act describes for cosmetics sold to consumers. |
| Who counts as a licensed professional | Individuals licensed by a state in cosmetology, nail care, barbering or esthetics. |
| The responsible person | The manufacturer, packer or distributor whose name appears on the label. |
| Fragrance allergens | To be listed on labels once FDA sets them by regulation; no rule yet. |
| Existing cosmetic label rules | Ingredients, net quantity and warnings under FDA rules and the FPLA continue alongside. |
Where it goes wrong
One approved set of product information ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up without the warnings or details these rules require.
Heldan Pro bond treatment: US adverse event contact (phone and website) and "For use only by licensed professionals"
How Arbitr helps
Read every version by hand? Or use AI to check what you publish against what you've already approved.
FAQ
Usually where a label is reused rather than redesigned. MoCRA's cosmetics labeling rules describe a domestic contact for adverse event reports and a professional-use statement,1 and we usually find gaps in:
Plan it as part of the US label set, not a sticker added at the border. Global artwork often carries only a European or Asian address, so record the approved US contact line once and check every pack size against it. Our packaging and labels page shows how teams keep label sets in step.
Keep one record per product: the approved contact line, any professional-use statement, the ingredient list, who approved each, and every pack, listing and feed it appears on. When the contact details or a formula change, the record shows which versions still carry the old ones.
How it applies to a specific label is a question for your legal adviser. Where that label appears across your markets and languages is a question Arbitr answers.
Regulatory teams usually own it, but packaging, e-commerce, salon sales and distributors all publish labels, and resellers republish them. A short briefing for each, using your own packs, helps. Rules for other markets, such as UKCA marking for Great Britain, are on our product labeling hub.
In two steps after MoCRA became law on December 29, 2022, according to the Act: the professional-use statement from December 29, 2023, and the adverse event contact on labels from December 29, 2024.1
Not as of October 2026. FDA lists fragrance allergen labeling among the regulations MoCRA requires it to establish, and its MoCRA page, last updated August 10, 2026, points to no proposed rule.2
They work together. FDA describes the FD&C Act and the Fair Packaging and Labeling Act as both requiring cosmetic firms to disclose information on their labels, and MoCRA added new items on top.3
Arbitr checks your content against the rules, claims and terms your team has approved, and reports where something doesn't match, by channel, market and language. It reports matches against your rules, not legal verdicts. What to do with each one stays with your team.
