2022 Law Still Reshaping FDA's Cosmetics Oversight, Alert Warns

A client alert from the law firm Crowell & Moring LLP, titled "Cosmetics Under the Microscope: FDA's Expanding Regulatory Reach Under MoCRA," flags a broader push by the U.S. Food and Drug Administration to oversee cosmetics makers, according to the firm's alert as circulated via Google News. MoCRA, the Modernization of Cosmetics Regulation Act, was enacted in 2022 and marked the first significant update to federal cosmetics law in decades.

What is MoCRA and why is FDA's reach expanding?

MoCRA replaced a regulatory framework that had left FDA with limited tools to police cosmetics beyond labeling and post-market complaints. The law gave the agency new administrative levers over how cosmetics companies register, report, and respond when products draw safety concerns. The Crowell & Moring alert's headline signals that FDA is now applying that authority more actively, though the firm's alert text itself was not made available beyond its title in the material reviewed for this report.

How does MoCRA compare with FDA's historical cosmetics authority?

Before MoCRA, cosmetics oversight traced back to the original Federal Food, Drug, and Cosmetic Act framework dating to 1938, under which FDA could not mandate a recall of a cosmetic product even if it posed a health risk. MoCRA's 2022 passage changed that baseline, giving the agency new administrative recall power and formalizing requirements such as facility registration and product listing that previously operated largely on a voluntary basis.

Data points

• 1938 — the year the original federal law governing cosmetics took effect, before MoCRA's overhaul.
• 2022 — the year MoCRA was enacted, updating FDA's cosmetics authority for the first time in decades.

What should cosmetics companies watch for now?

The alert's framing — describing cosmetics as being placed "under the microscope" — points to continued scrutiny as FDA implements MoCRA's provisions. Companies in the space typically track:

• Facility registration and product listing obligations with FDA
• Recordkeeping tied to safety substantiation for marketed products
• Adverse event reporting and recall-readiness procedures

Does this affect how consumers evaluate skincare claims?

For buyers, tighter federal oversight of ingredient safety documentation intersects with consumer interest in evidence-based skincare choices, a theme also addressed in HTT's own reporting on science-backed skin care routines, which notes that verifying ingredient claims is central to routine-building.

Where can readers find the primary source?

The Crowell & Moring alert is referenced via Google News. Readers seeking the full legal analysis, including any specific compliance deadlines or enforcement examples, should consult the firm's published alert directly, as this report relies on the publicly circulated headline and title rather than the complete memo text.