Cosmetic Manufacturers Preparing For MoCRA Safety Substantiation Should Look To EU – Attorneys

Manufacturers looking for a model of safety substantiation in order to comply with the US Modernization of Cosmetics Regulation Act of 2022 should consider the framework required by the EU’s Cosmetic Products Regulation, says Steptoe & Johnson associate Surya Kundu. Attorneys also discussed new requirements for adverse event reporting during a FDLI webinar on MoCRA.

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The EU’s safety substantiation standard for cosmetic products is a good model for manufacturers to consult as they work to comply with the US Modernization of Cosmetics Regulation Act of 2022.

“To the extent that you can leverage these EU standards, look at the quality of the testing that the EU is requiring and use that to establish that your tests are similarly credible, that they would be considered reliable by other authorities in the field,” said Surya Kundu, associate of

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