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When Congress enacted the Modernization of Cosmetics Regulation Act in 2022, MoCRA was hailed as a sweeping overhaul of the Food and Drug Administration’s…


United States
Food, Drugs, Healthcare, Life Sciences


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When Congress enacted the Modernization of Cosmetics Regulation
Act in 2022, MoCRA was hailed as a sweeping overhaul of the Food
and Drug Administration’s cosmetic safety and quality
standards. Yet, years later, MoCRA has largely stalled. FDA is
notably delayed in enacting manufacturing and labeling rules, and
the broad regulatory freeze under the Trump administration means
FDA’s lack of movement on MoCRA will likely continue.

But the beauty industry is not in regulatory limbo. On the
contrary, sweeping change is here—at the state level.

At least 17 states have passed “toxic free laws.” Some
are already in effect, others take effect in 2026 and 2027, and
even more bills are working their way through state legislatures
across the country.

Toxic-free laws restrict or ban allegedly harmful ingredients in
consumer products, including cosmetics and personal care
products.

In essence, states are legislating “clean beauty.”

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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