Document Type
Oral Presentation
Location
Oxford Convention Center, 102 Ed Perry Boulevard Oxford, MS 38655
Event Website
https://oxfordicsb.org/
Start Date
17-4-2024 2:00 PM
End Date
17-4-2024 2:30 PM
Description
The Modernization of Cosmetics Regulation Act (MoCRA) enacted by Congress December 29th, 2022, includes provisions for the FDA to publish proposed Good Manufacturing Practice (GMP) regulations by the end of 2024 and a final rule by the end of 2025. In this talk we will explore what the language of MoCRA tells us about what GMPs are likely to be promulgated with a focus on GMPs related to ingredient and finished product identity and purity. MoCRA exempts small cosmetics manufacturers from GMP compliance requirements and directs FDA to “take it easy” on other not-quite-so-small manufacturers. Despite these exemptions, most cosmetics manufacturers are likely to find themselves subject to complying with these GMPs, as MoCRA is just part of a broader paradigm shift impacting this and other consumer product categories. Modern consumers are informed, and increasingly demand proven safe, pure, authentic products. This demand is reflected in the proliferation of state level ingredient bans, consumer litigation and a vast market for “clean” and “natural” products. For these and other reasons we will examine, noncompliance is a losing long-term strategy for cosmetics brands.
Recommended Citation
Reinbold, Brandi, "MoCRA and the new Cosmetics GMPs" (2024). Oxford ICSB. 23.
https://egrove.olemiss.edu/icsb/2024_ICSB/Schedule/23
Publication Date
April 2024
Accessibility Status
Searchable text
Included in
MoCRA and the new Cosmetics GMPs
Oxford Convention Center, 102 Ed Perry Boulevard Oxford, MS 38655
The Modernization of Cosmetics Regulation Act (MoCRA) enacted by Congress December 29th, 2022, includes provisions for the FDA to publish proposed Good Manufacturing Practice (GMP) regulations by the end of 2024 and a final rule by the end of 2025. In this talk we will explore what the language of MoCRA tells us about what GMPs are likely to be promulgated with a focus on GMPs related to ingredient and finished product identity and purity. MoCRA exempts small cosmetics manufacturers from GMP compliance requirements and directs FDA to “take it easy” on other not-quite-so-small manufacturers. Despite these exemptions, most cosmetics manufacturers are likely to find themselves subject to complying with these GMPs, as MoCRA is just part of a broader paradigm shift impacting this and other consumer product categories. Modern consumers are informed, and increasingly demand proven safe, pure, authentic products. This demand is reflected in the proliferation of state level ingredient bans, consumer litigation and a vast market for “clean” and “natural” products. For these and other reasons we will examine, noncompliance is a losing long-term strategy for cosmetics brands.
https://egrove.olemiss.edu/icsb/2024_ICSB/Schedule/23