FDA Update: Revised Timelines for MoCRA Implementation and Cosmetic Regulations

Delsie Braganza

Delsie joined the Focal Point Research team in 2011 and has been an invaluable asset for our clients. With her strong regulatory and quality assurance background, she is able to help clients understand the Canadian and US requirements, set targets to achieve compliance, and attain their goals to get products to market.

Delsie is able to audit facilities, set up and maintain GMP compliant facilities, develop strong quality management systems, and co-ordinate successful Health Canada inspections. In addition to this, Delsie oversees all regulatory compliance reviews and submissions made to Health Canada and the US FDA.

Delsie obtained an Honours Bachelor of Science (Hons. B. Sc.) in Pharmaceutical Chemistry from the University of Toronto, Post-Graduate Certificate in Pharmaceutical Regulatory Affairs and Quality Operations (RAQ) from Seneca College and Regulatory Affairs Certification (RAC) from the Regulatory Affairs Professional Society (RAPS).

When she’s not learning something new, Delsie loves spending time with family, going on road trips or long walks, and swimming.

Jennifer Porter, BA Psychology, MBA – President & CEO

Having started at Focal Point Research in 2011, Jenn has been fully engaged in the company and since day one, has leveraged her MBA and interest in the regulated products industries to grow her passion for the business and services offered.

Jenn has excelled at building on initial conversations with a variety of companies from all industries seeking regulatory and quality assurance services. She has developed strong relationships with each client, offering each one a unique opportunity to have the Focal Point Research team help them develop successful strategies and bring products to market, while ensuring their compliance needs are being fulfilled.

Jenn has not only been a leader internally, but a key contact for all clients and in 2021, Jenn was the obvious choice to lead Focal Point Research into the future as the successor to company founder, Rob Fichtner.

Jennifer balances her career by honouring her wanderlust, spending her leisure time golfing, and enjoying the outdoors with her loving dog.

On July 3, the Department of Health and Human Services (HHS) published the latest Unified Agenda and Agency Rule List. This publication offers updated insights into the FDA’s expected timeline for implementing the Modernization of Cosmetics Regulation Act (MoCRA) and other cosmetics-related rules.

While the published dates are not legally binding, and cosmetics rulemaking has historically experienced further delays following the publication of these target dates, the agenda outlines the latest thinking from the HHS and FDA regarding their regulatory timelines.

Key Updates to Proposed Target Dates:

The agenda highlights new proposed dates for several critical regulatory actions:

Disclosure of Fragrance Allergens: The new proposed date for the disclosure of fragrance allergens in cosmetic labeling is November 2026.

Formaldehyde in Hair Products: The new proposed date for rules addressing the use of formaldehyde and formaldehyde-releasing chemicals as an ingredient in hair smoothing products or hair straightening products is November 2026.

Good Manufacturing Practice (GMP): The new proposed date for Good Manufacturing Practice for cosmetic product facilities is November 2027.

Asbestos Testing in Talc: The new proposed date for testing methods for detecting and identifying asbestos in talc-containing cosmetic products is November 2027.

What This Means for the Industry:

These revised target dates indicate continued delays in the finalization of key MoCRA provisions. However, this extension provides manufacturers, brand owners, and regulatory teams with additional time to prepare. Companies should use this window to proactively review their formulations, audit their manufacturing processes, and establish the necessary supply chain transparency to ensure full readiness once the FDA finalizes and enforces these mandates.

If you have any questions or need assistance with MoCRA listings, label or formulation reviews, reach out today.

Delsie Braganza

Jennifer Porter, BA Psychology, MBA – President & CEO

FDA Update: Revised Timelines for MoCRA Implementation and Cosmetic Regulations

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