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MoCRA’s Adulteration Ambiguity And FDA’s New Cosmetic Recall Authority: Attorney Weighs In

 
• By Eileen Francis

The US FDA should use guidance or rulemaking to clarify MoCRA provisions related to adulteration, Amin Wasserman Gurnani attorney Angela Diesch suggested at the Independent Beauty Association’s Cosmetics Convergence Spring Symposium. Attendees also sought her take on whether the agency’s new recall authority is likely to spell an increase in cosmetic product recalls.

• Source: Shutterstock

The Modernization of Cosmetics Regulation Act is a touch ambiguous in a section concerning cosmetic product adulteration, which could pose legal questions for small manufacturers, says Angela Diesch, an attorney with Amin Wasserman Gurnani, LLP.

Speaking at the Independent Beauty Association’s Cosmetics Convergence Spring Symposium on 11 April, Diesch pointed out that small businesses are exempt from good manufacturing practices (GMP) compliance, as well as facility

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