Beginning in 2024: The Impact of Large-Scale Changes in Cosmetic Labels
For the manufacturers, marketers, and distributors of cosmetic products, expect to include added information on product labels in 2024. This results from the Modernization of Cosmetic Regulation Act (MoCRA), considered the most significant expansion of the Food and Drug Administration’s (FDA) authority in nearly 90 years. The FDA passed the Act in December 2022, with some key components going into effect as of the end of December 2023.
But the FDA has extended some deadlines until July 1, 2024. This will give manufacturers and marketers extra time to update their product labels per the Act’s requirements.
For those marketers of cosmetic products unfamiliar with the Act, here are some of the changes that will be required on cosmetic product labels:
- The label must include contact information.
- This contact information must include a domestic address, domestic phone number, website, or email address so that consumers can easily report adverse effects of the product.
- Whether manufacturer or distributor, the company mentioned on the label must keep their customer contact information current.
- The label must include information that the product is safe for consumers. This might consist of tests, studies, or scientific research. This information should also be readily available to distributors.
- The FDA will release a list of fragrance allergens, and the labels of cosmetic products are now required to list any such allergens on their product labels.
- The company or a person’s name on the label will be considered the organization’s “responsible person.” They are responsible for reporting adverse side effects of the product to the FDA.
- The manufacturer or distributor must also report any adverse side effects collected from consumers within fifteen business days of the initial report from the consumer.
MoCRA also requires that cosmetic manufacturers register their products with the FDA and renew this registration biannually. To simplify the process, the FDA has created a website, Cosmetics Direct, which allows for electronic registration.
What This Means for You
According to Kate Nash, director of sales for a supplier and distributor of a cosmetics company, “This is a huge change for our industry…. the FDA looks [to see] who is responsible for a product’s labeling, safety, and more.”
She adds, “MoCRA represents a new shared responsibility between manufacturers and distributors that didn’t exist before for cosmetics.
“It’s common in our industry for a distributor to be listed on a label as ‘Distributed by.’ With MoCRA, the company listed on the cosmetic label is now responsible for registering a product, having systems in place to report adverse effects, having documentation on the product’s safety, and being prepared for recalls if one should occur – whether or not they are the manufacturer.”
What’s happening in the cosmetic industry is also relevant for the food industry, where product safety information on labels has long been critical for consumers.
According to a Food Industry Association study from January 2022, more than half of shoppers are willing to switch brands if they find another brand offering more detailed product information on the label.
The trend for more detailed consumer safety information will likely spread to all types of products and product labels from many industries. Manufactures should view this not as a problem but as an opportunity. By being proactive and adding this information on their labels now, they can gain an advantage over their competitors, who likely will need to play catch up to meet these labeling requirements – and retain their customers – in the future.
Partnering with a label manufacturer like GENflex Labeling Solutions will help manufacturers keep up with the latest standards and regulations on product labels. Have questions, just ask.
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