If you sell cosmetics in the US, MoCRA has quietly rewritten what has to appear on your packaging, and mid-2026 is a turning point: one FDA rulemaking deadline just slipped again, another is due any month, and brands searching for a straight answer keep landing on outdated blog posts.
Getting the distinction between already-enforceable and still-pending wrong is expensive either way. Miss a live requirement and you risk an FDA warning letter; redesign your label around a rule that doesn’t exist yet and you’ve wasted a print run. This guide separates the two clearly, adds the current status of every open MoCRA rulemaking, and gives you a concrete packaging audit checklist.
Quick Answer
MoCRA already requires every cosmetic label to list a domestic address, domestic phone number, or electronic contact (such as a website) where the responsible person can receive adverse event reports — enforceable since December 29, 2024. Fragrance allergen disclosure and cosmetic GMP rules are both still stuck in FDA rulemaking as of mid-2026, so neither is mandatory on labels yet. Facility registration and product listing are separate, already-enforced MoCRA obligations most brands should have handled by now.
What Actually Changed on the Label
Before MoCRA, cosmetic labels were governed mainly by the Fair Packaging and Labeling Act and existing FDA cosmetic labeling rules: ingredient lists, net quantity, manufacturer or distributor name and address, and applicable warning statements. MoCRA layered one new, specific requirement on top — the label must give consumers a way to report adverse events directly to the responsible person: a domestic address, a domestic phone number, or an electronic contact method such as a website or monitored email. At least one of these must be clearly present on the label.
The responsible person is the manufacturer, packer, or distributor whose name already appears on the label under the FD&C Act and the Fair Packaging and Labeling Act. If that’s your brand, you’re legally on the hook for maintaining adverse event records for six years (three years if you qualify as a small business) and reporting serious adverse events to FDA within 15 business days, along with a copy of the product label.
MoCRA Packaging: What’s On the Label vs. What Isn’t Regulated
MoCRA is a labeling and reporting law, not a packaging-materials law — it doesn’t dictate container type, recyclability, or child-resistant closures. Where it intersects with your physical packaging is the label copy and warning statements printed on it.
Cosmetics in self-pressurized containers, including deodorant and antiperspirant sprays, hairsprays, and other aerosols, still need the long-standing FDA warning statement covering contents under pressure, avoiding spraying in eyes, not puncturing or incinerating the container, and not storing above 120°F. If the propellant is a hydrocarbon or halocarbon, a second warning against deliberate inhalation misuse is also required. These warnings must be in bold type on a contrasting background, at least 1/16 inch tall. None of this is new under MoCRA, but it’s exactly the kind of existing warning-label rule brands overlook while focused on the newer adverse-event contact line — check both during the same packaging audit.
Fragrance Allergen Disclosure: Where the Rule Stands Right Now
FDA missed its original June 29, 2024 statutory deadline to propose fragrance allergen disclosure rules. Per FDA’s own Unified Agenda, the agency had targeted May 2026 for publishing that proposed rule. As of mid-2026, no proposed rule has appeared in the Federal Register, so there is still no fragrance allergen list or disclosure threshold mandatory on any US cosmetic label.
When a proposed rule does land, expect a public comment period before anything becomes final and enforceable — realistically 2027 or later. Expect FDA to reference frameworks already used elsewhere, such as the EU’s list of designated fragrance allergens. Start pulling fragrance and essential-oil supplier documentation now so you’re not caught flat-footed, but don’t redesign a label around a rule that hasn’t been published.
The Cosmetic GMP Rule: Also Delayed, Not Coming Soon
MoCRA also required FDA to issue cosmetic good manufacturing practice regulations by December 29, 2024. That deadline was missed too, and FDA’s proposed GMP rule has since been moved to the “long-term action” list on its own regulatory agenda — a signal the agency doesn’t expect to publish it within the next year. Until a final GMP rule exists, there’s no new mandatory labeling or recordkeeping requirement tied to it, though many brands are voluntarily aligning production controls with ISO 22716 in anticipation.
Facility Registration, Product Listing, and the Small Business Exemption
Facility registration and product listing are separate from labeling but already enforced. Facilities that manufacture or process cosmetics for the US market have needed to register with FDA since December 29, 2023, with renewal required every two years, and each marketed product generally needs to be listed, including its ingredients, within 120 days of first being marketed.
Brands with average gross annual US cosmetic sales under $1 million over the prior three years qualify for the small business exemption from registration, listing, and GMP rules. That exemption does not extend to labeling, safety substantiation, or adverse event reporting, and it disappears entirely if you sell even one non-exempt product category — for example, anything intended for injection or for altering appearance for more than 24 hours.
Step-by-Step: Audit Your Packaging Before Your Next Print Run
Work through every SKU in one pass. Confirm the adverse-event contact line first: a domestic address, domestic phone number, or a monitored electronic contact such as a working website or email. If packaging predates December 2024, that’s the first fix on your next run.
Then check any pressurized or aerosol product for the correct FDA warning statement and, if applicable, the hydrocarbon/halocarbon inhalation warning. Confirm facility registration is current and due for renewal on schedule, and that every SKU you sell is listed with FDA. Don’t add a fragrance allergen disclosure or wait on a GMP-driven relabel — neither rule exists yet. If you sell professional or salon-use-only products, watch for FDA guidance on separate professional-use labeling, an area MoCRA touches on but hasn’t finalized.
Common Mistakes to Avoid
The most common mistake is redesigning a label around a fragrance allergen list that doesn’t exist, based on posts predicting what FDA “will soon” require. Check FDA’s own MoCRA page or a legal alert dated within the last few months before treating any allergen requirement as active. Don’t list an unmonitored PO box or fulfillment center as your adverse-event contact — the requirement is functional; someone actually has to receive and act on reports. And don’t assume small business status exempts you from labeling: the exemption covers registration, listing, and GMP rules, not what has to appear on the label itself.
MoCRA labeling requirements FAQs
What are the MoCRA labeling requirements?
MoCRA requires every cosmetic label to include a domestic address, domestic phone number, or electronic contact (like a website) so consumers can report adverse events to the responsible person. This has been enforceable since December 29, 2024. It’s added on top of existing FDA labeling rules like ingredient lists, net quantity, and warning statements — it doesn’t replace them.
What does MoCRA actually require right now, in 2026?
Enforceable today: the adverse-event contact line on labels, facility registration (renewed every two years), and product listing. Still pending FDA rulemaking: fragrance allergen disclosure and cosmetic GMP regulations. Neither is a current labeling requirement.
Is there an FDA MoCRA update for mid-2026?
The main development is on the fragrance allergen front: FDA’s Unified Agenda had targeted a proposed rule for May 2026, but as of mid-2026 no proposed rule has been published in the Federal Register. The GMP rule has also been pushed to FDA’s long-term action list, meaning it’s not expected within the next year.
Does MoCRA require fragrance allergens to be listed on cosmetic labels?
Not yet. MoCRA directed FDA to issue a fragrance allergen disclosure rule, but FDA missed its original 2024 deadline and, as of mid-2026, still hasn’t published even a proposed rule. There is no mandatory fragrance allergen list on US labels right now.
What warning label does a deodorant or antiperspirant spray need?
Aerosol deodorant and antiperspirant sprays need FDA’s standard pressurized-container warning: avoid spraying in eyes, contents under pressure, don’t puncture or incinerate, don’t store above 120°F. If the propellant contains a hydrocarbon or halocarbon, a second warning against deliberate inhalation misuse is also required. This predates MoCRA but still applies alongside the newer adverse-event contact line.
Does MoCRA affect cosmetic packaging materials?
No. MoCRA is a labeling and safety-reporting law, not a packaging-materials regulation — it doesn’t govern container type, recyclability, or closures. Its packaging impact is limited to what’s printed on the label: the new adverse-event contact requirement plus existing warning statements.
Are small businesses exempt from MoCRA?
Only partially. Brands with average gross annual US cosmetic sales under $1 million over the prior three years are exempt from facility registration, product listing, and GMP rules. That exemption does not cover labeling, safety substantiation, or adverse event reporting, and it’s lost entirely if you sell even one non-exempt product type, such as injectable or long-lasting appearance-altering products.
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