Under the federal Modernization of Cosmetics Regulation Act (MoCRA), most companies that manufacture or process cosmetics sold in the United States must register their facilities with the FDA and renew that registration every two years; as of June 30, 2026, the agency's Cosmetics Direct portal logged 16,398 active facility registrations and more than 1.29 million active product listings, according to the FDA.
That figure matters now because the law's first full renewal cycle has just started clearing. A facility that registered on February 20, 2024, when enforcement of the original registration deadline began, owed its first renewal by February 20, 2026, per the FDA's own registration and listing guidance. To help facilities track that clock, the agency added two fields to Cosmetics Direct in February 2026 — registration status and renewal date — along with automated reminder emails ahead of each due date, the FDA says.
What does MoCRA actually require?
Two obligations run in parallel. Manufacturers and processors register their facilities and renew biennially; separately, the responsible person — defined by the FDA as the manufacturer, packer, or distributor whose name appears on the product label — must list each marketed cosmetic, including its ingredients, with updates required annually. The two records link: a product listing must carry the registration number of the facility that made it. Registration changes, such as a change of ownership or a new manufacturing site, must be reported within 60 days, according to the FDA.
Which small businesses are exempt — and which aren't?
MoCRA exempts certain small businesses from both facility registration and product listing, though the FDA's own small-business fact sheet does not publish a specific revenue or headcount threshold in the document itself, pointing instead to more detailed draft guidance. What the fact sheet does spell out clearly are the products the exemption never covers, regardless of a company's size: anything that regularly touches the eye's mucous membranes, anything injected, anything meant for internal use, and anything designed to alter appearance for more than 24 hours where a consumer wouldn't normally remove it. A small, independent lash-serum or semi-permanent-tint maker, in other words, can be too small to need a marketing budget and still fall inside MoCRA's registration requirement because of what the product does.
The other MoCRA deadline: adverse event reporting
Registration isn't the only clock beauty companies have been on. A separate MoCRA provision, effective December 29, 2023, requires cosmetic companies to record and report serious adverse events tied to their products. "MoCRA will have an enormous, positive impact on the safety of cosmetics, significantly changing how cosmetic providers deal with product safety, labeling and reporting," Dr. Leo Sioris said in a statement distributed by SafetyCall International, a poison-control and compliance firm that says it worked with the FDA and industry trade groups during the law's development. The statement is from a company with a commercial interest in cosmetics-compliance consulting, and it does not itself define what qualifies as a serious event or lay out specific recordkeeping timeframes — those specifics live in the FDA's own guidance, not in the release.
Why it's a New York story
New York's beauty economy runs heavily on small and mid-sized brands — the kind of Brooklyn-formulated serum or SoHo-launched fragrance house most likely to sit right at the edge of MoCRA's small-business line. For a founder deciding whether a new tint, lash treatment, or long-wear product needs a federal facility registration, the exemption's product-based exceptions, not a company's size, are what actually decide the question. The FDA's own numbers — over 16,000 registered facilities and 1.29 million listed products nationwide as of this summer — suggest a compliance apparatus that's now fully operational rather than newly standing up, which is its own signal to any brand still treating registration as optional.
What the evidence here doesn't show: neither the FDA's registration page nor its small-business fact sheet discloses enforcement actions or penalty amounts tied to missed renewals, and the exact small-business revenue threshold remains published only in FDA draft guidance rather than in the fact sheet itself. Brands with questions about where they fall are directed to that guidance, not to this article.
This piece is informational reporting on federal regulatory requirements, not legal or regulatory advice; a company's specific registration and listing obligations should be confirmed with qualified regulatory counsel or directly with the FDA.
For a related beauty news perspective, read The Fragrance Line on Every Label: What MoCRA's Allergen Rule Will (and Won't) Change.