Product Compliance
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In2025,The US cosmetics regulatory system is undergoing its most important round of reshaping in decades.From a federal perspective MoCRA Fully implemented,to OTC Sunscreen regulatory reform,Continuing to increase in various states Chemical Substance Restriction Regulations,The compliance requirements for cosmetics in the US market are undergoing structural changes.This article will systematically review and organize the system 2025 Key regulatory developments that have been implemented or officially promoted in the year,Key points What has changed When must compliance be achieved And what these changes mean for cosmetics companies.
One MoCRA continuously advance FDA Comprehensive upgrade of cosmetics regulation
Modernization Act for Cosmetics Regulation Modernisation of Cosmetics Regulation Act,abbreviation MoCRA self 2023 Annual inclusion omnibus appropriation bill since,in the process of 2025 Entering the stage of comprehensive implementation and law enforcement in the year,Has a profound impact on the compliance system of cosmetics in the United States.
MoCRA Significantly expanded FDA Regulatory authority over cosmetics,The core changes include
● Compulsory Factory Registration Facility Registration
● Product List Declaration Product Listing
● Mandatory reporting mechanism for serious adverse reactions
● All cosmetics sold in the United States must have a safety basis Safety Substantiation
among which,The most strategically significant authorization is FDA Mandatory cosmetics can be formulated GMP Good Manufacturing Practice regulation.The relevant rules are still being formulated at present,But this marks that the United States is moving away from the past Mainly based on voluntary compliance The pattern,Gradually shifting towards a strong regulatory system similar to the European Union.
Summary points
MoCRA Fundamentally raising the compliance responsibility threshold for enterprises,by registering filing Safety assessment and adverse reaction management,Bring the US cosmetics regulatory system closer to the standards of mature markets such as the European Union.
Two OTC Sunscreen reform the United States UV Filter innovation channel reopened
2025 Another milestone change of the year,From the regulatory reform of sunscreen products in the United States.
in the U.S.,Sunscreen products are used as over-the-counter drugs OTC drugs manage,This regulatory framework has long restricted technological innovation in history,Resulting in new developments for decades UV Filter cannot be approved.2025 The reform of the year aims to FDA Modernize the way of evaluating sunscreen active ingredients,Including accelerating the review process Introduce more advanced scientific evaluation methods,And gradually get rid of outdated testing modes.
expected FDA will be 2025 Release updated sun protection regulatory rules before the end of the year,and 2026 year pair UV Conduct substantive evaluation of filters.This change will directly affect ingredients that have been approved and used in markets outside the United States,For example, widely used in the European Union and South Korea Bemotrizinol.Although the relevant ingredients do not automatically obtain approval from the United States,But this reform has established for the first time a system that did not exist before A feasible regulatory path with practical feasibility.
Summary points
US sunscreen regulatory reform for higher protection Sunscreen products with better skin feel open the door,Nearly twenty years have come to an end UV Filter agent stagnate The situation.
Three PFAS Control upgrade State regulations become key compliance variables
Comprehensive measures have not yet been introduced at the federal level PFAS Perfluorinated and polyfluoroalkyl substances Against the backdrop of the ban,2025 Several states in the United States have significantly accelerated their efforts in the past year PFAS The regulatory pace.
currently,including California State Washington State Colorado Maryland Multiple states within it,Implemented or started to implement targeting Intentionally added PFAS The cosmetics ban .
California Starting January 1, 2025, the sale of cosmetics containing intentionally added PFAS will be prohibited
Other states The scope of the ban and enforcement time may vary slightly,But the overall trend is consistent
this kind of State led The regulatory model,Resulting in a highly fragmented compliance environment for cosmetics in the United States.Merely meeting federal regulations is no longer sufficient,Enterprises must make formulation decisions based on the strictest state regulations as a compliance benchmark.
Four not only PFAS state-level Non toxic Cosmetics Law continuous expansion
except PFAS outside,Some states are pushing for more comprehensive chemical substance restriction systems.
among which,Washington State Toxic-Free Cosmetics Act Non toxic Cosmetics Law representative,This regulation is not limited to PFAS,also include
● Components that release formaldehyde
● Specific heavy metals
● Other identified as Pay attention to chemical substances The raw materials
This type of regulation reflects a clear trend Chemical Safety Policy for Cosmetics in the United States,More efforts are being made at the state level to promote it,Rather than federal unified legislation.
Summary points
Although there is currently no nationwide PFAS Comprehensive ban,But California Washington State Expanding state-level restrictions such as New York State,It is actually forcing the industry to gradually phase out this type of product Permanent chemicals .
Five Talc powder and asbestos Regulatory rules are still in an uncertain state
In talc powder Talc Related risk management aspects,FDA Recently, a proposal to require a unified asbestos testing standard for cosmetics containing talc powder was officially withdrawn.
FDA express,Need to reassess the best regulatory path,In response to the complex science received during the rule making process Technical and policy feedback.currently,The new regulations will be reissued,But there is no clear timetable yet.
During this transitional phase,Although regulations have not yet been enforced,Enterprises are still widely advised to take proactive risk management measures,including
1. Raw material supplier audit
2. Quality Agreement and Quality Control
3. Batch testing and risk assessment
Six What does it mean for cosmetics companies
In summary, the US cosmetics regulatory environment in 2025 will exhibit three main characteristics:
1. MoCRA Strengthen systemic supervision at the federal level
2. sunscreen OTC Reform revitalizes ingredient and product innovation
3. State level regulations continue to raise the safety threshold for ingredients
2025 is not the end of tightening regulations on cosmetics in the United States, but the beginning of a new normal. The sooner a systematic and forward-looking compliance management mechanism is established, the more proactive companies will be in future competition in the US market.