MoCRA under Trump: What’s at Stake?

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) represents the first major update to U.S. cosmetics regulation since the Federal Food, Drug, and Cosmetic Act of 1938. It aims to enhance consumer safety through new requirements around facility registration, product listing, serious adverse event reporting, safety substantiation, mandatory recall authority, and more.

The Resource Challenge Under Trump

The Environmental Working Group highlighted how the Trump administration’s broader priorities—including potential funding cuts and staffing instability—could significantly hinder the FDA’s ability to enforce MoCRA’s provisions. Reduced budgets and agency personnel might delay safety reviews and weaken enforcement efforts, potentially allowing smaller cosmetic brands to bypass their regulatory responsibilities.

MoCRA Enforcement Continues (for Now)

Despite worries about a regulatory pullback, Crowell & Moring LLP reports that in the early months of the Trump administration, the FDA continued to implement MoCRA effectively. As of January 1, 2025, the agency had received 9,528 active facility registrations and 589,762 product listings, compared to 5,176 registrations and 35,102 listings under the old voluntary program (VCRP). This jump underscores MoCRA’s mandatory nature and the agency’s functional momentum.

Moreover, the FDA issued warning letters to three drug manufacturers, reminding them that some of the products they make may fall under MoCRA’s jurisdiction—as cosmetics—and must comply accordingly. This demonstrates that FDA actions continued under Trump, mirroring prior administration patterns.

Regulatory Freeze: A Lingering Threat

On August 2, 2025, a commentary on In My Kit noted that a broader "regulatory freeze" had cast uncertainty over progress with MoCRA. The article asserts that key provisions of the law have been put on hold, impacting manufacturers, brands, and consumers alike. Unfortunately, the post is behind a paywall and doesn't offer full details.

FDA’s Official Position

From the FDA’s communications:

  • Facility registration and product listing are mandatory; registration must be renewed biennially. The agency can suspend a facility’s registration if the products pose serious health risks.
  • Serious adverse event (SAE) reporting requires responsible persons to report within 15 business days using Form FDA 3500A; updates based on new information must also follow the same timeline.
  • The FDA has released guidance on how to comply with registration and listing, and the final guidelines were published in December 2023 and updated in December 2024.

Ultimately, the fate of MoCRA under the Trump administration remains caught between demonstrated early enforcement progress and the looming possibility of slowed or stalled implementation. While the FDA has shown it can execute the law’s requirements—ramping up registrations, issuing guidance, and taking compliance action—the sustainability of these efforts depends heavily on political will, stable funding, and regulatory continuity. For consumers, the stakes are high: MoCRA promises stronger safeguards in an industry that touches millions of lives every day. Whether those promises are fully realized will hinge on whether current momentum can withstand the pressures of shifting administrative priorities.

Key Takeaways: The Blog Breakdown

  • Legislation: MoCRA is critical for modernizing cosmetics safety and regulatory oversight.
  • Implementation Status: As of early 2025, FDA compliance actions (registrations, listings, warning letters) continued under Trump, aligning with prior enforcement patterns.
  • Threats & Uncertainty: Budget cuts, staffing pressures, and a regulatory freeze pose risks to MoCRA’s long-term implementation.
  • FDA’s Role: The agency has clear authority and is backed by guidance and tools to enforce MoCRA—but its effectiveness depends on sustained support and clarity in regulations.
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