In July 2020 after four years of motions practice, Unilever United States, Inc. was granted summary judgment in a putative class action alleging that the company endangered consumers with its deceptively advertised St. Ives Apricot Scrub.
MoCRA-Required Recordkeeping, Reporting Now ‘Fair Game’ For Litigants – Crowell & Moring
Cosmetic product manufacturers can expect the plaintiffs’ bar to leverage new record-keeping, GMP and other provisions of the Modernization of Cosmetic Regulations Act to bring or advance litigation, Crowell & Moring attorneys say. They note some defensive tactics that could prove effective.

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Cosmetic companies should conduct audits to identify products that will be required to disclose fragrance allergens and begin the work of adjusting labels, particularly for smaller packaging, says a director at Registrar Corp., during a 12 March webinar on MoCRA and labeling.
Cosmetics companies brace for the impact of Trump administration tariffs as industry experts seeing an opportunity for an exemption urge stakeholders to reach out to lawmakers. The issue was discussed during PCPC’s recent Beauty Collective Summit.
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