MoCRA product listing: what you file and who files it
Under MoCRA, each cosmetic marketed in the US must be listed with FDA (FD&C Act §608): product category, ingredients, and label copy, filed by the responsible person whose name is on the label. Facility registration (§607) is the companion duty.
Short answer: MoCRA requires the responsible person — the manufacturer, packer, or distributor whose name appears on the label — to list each cosmetic product with FDA under FD&C Act §608, including the product category, its ingredients, and the label as used. Facility registration under §607 is the companion duty. The US already enforced this regime before our last check; see the FDA pages for current deadlines.
What a listing contains
| Item | Where it comes from |
|---|---|
| Product name and category | FDA's category structure for cosmetics |
| Full ingredient list | The formula, ingredient by ingredient |
| Product label as used | The same label artwork that ships |
| Facility registration number(s) | From the §607 facility registration |
Who files
The duty sits with the responsible person named on the label — not automatically with the contract manufacturer. A small brand that has its products made by a US or overseas lab still lists the products itself if its name is on the label. A brand selling products already listed by another responsible person does not list the same product twice.
Common mistakes
- Assuming facility registration covers product listing. They are two separate filings under two separate sections (§607 and §608).
- Listing under the contract manufacturer's name when the brand's name is on the label.
- Treating the listing as one-time. Listings must be kept current — content changes to the formula or label flow into the filing.
- Waiting until launch. The listing has to exist before the product is marketed; the FDA page states the timeline in force at any moment.
Sources
- FD&C Act §607 (facility registration) and §608 (product listing), as added by MoCRA — fda.gov MoCRA overview
- FDA, facility registration and product listing for cosmetics — fda.gov
- 21 CFR 701.13, principal display panel requirements, for the label copy the listing references — eCFR, issue 2026-11-06
Last verified: 2026-11-10. Filing deadlines and any FDA enforcement dates are stated on the FDA pages above; confirm them there rather than relying on secondhand summaries.
Not legal advice, and not a guarantee of compliance or of acceptance by any authority.
Want this checked against your own formula? Run the free label check. It produces the ingredient and label content you need for a listing, plus the label-compliance issues to fix first. It returns an issue list, not a print-ready label.
Related: MoCRA facility registration · MoCRA label requirements