MoCRA Check-In: Postscript To My Three Minutes At US FDA's Cosmetics GMP ‘Listening Session’

EAS Consulting Group’s John Bailey is checking in with HBW Insight periodically in 2023 to offer his views on developments under the US Modernization of Cosmetic Regulations Act of 2022. Here he provides his experience with, and takeaways from, the US FDA’s 1 June virtual “listening session” on good manufacturing practices for cosmetic products.

MoCRA Check-In
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Among the many provisions enacted by the Modernization of Cosmetics Regulations of 2022 (MoCRA) is the requirement that FDA promulgate regulations that establish Good Manufacturing Practices (GMPs) specifically for cosmetics.

This is a long, multistep process that will be challenging for FDA to complete by the required deadline. It is important to understand that, as with drugs and foods, GMP regulations impose a heavy burden on the regulated industry. FDA will enforce the new GMPs regulation primarily through establishment inspections

MoCRA GMP Provisions

Under MoCRA, FDA is directed to do the following:

  • By regulation establish good manufacturing practices for facilities that are consistent, to the extent practicable, and appropriate, with national and international standards;

  • Ensure that the regulations protect the public health and ensure that cosmetic products are not adulterated;

  • Inspect records necessary to demonstrate compliance with GMPs during an inspection conducted under section 704 (establishment inspections);

  • Include simplified GMPs for smaller businesses;

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