On March 13th, 2025, the FDA announced the number of cosmetic facility registrations and cosmetic product listings that had been completed under MoCRA in the last year.
Facility Registrations
From December 18th, 2023 until January 1, 2025, there were 9,528 facility registrations submitted to the FDA. That’s over 9000 facilities that are making cosmetics!
It turns out that of those, 1,800 were from the US (with California, Florida, and Texas being the top three states). There were another 7,732 product registrations from foreign facilities. If a company is going to sell products inside the US, even if they are being made outside the US, they still must register their facility. Of those foreign registrations, 4,260 were from China. None of the other countries had more than 1,000 facilities.
Product Listings
For product listings, there were 589,762 unique products listed. And remember that a product can be listed just once when there are different variations of that product based on size, color, or fragrance. So in actual fact there were probably more products out on the market than just those 589,762 products. That’s a lot of products!
Compared to the Voluntary Program
If you compare it with the Voluntary Cosmetic Registration Program (“VCRP”) that was in effect from 1972 until March of 2023, the numbers are pretty amazing. Under the VCRP (as of when it shut down in March of 2023) there were only 5,176 active establishments registered, and only 35,000 product filings. So obviously, MoCRA is collecting a lot more information about the cosmetic facilities and products that are on the market.
Who has to Register
Companies are required to register their cosmetic facilities and products with the FDA if they are not exempt as a small business. To be exempt as a small business, you must have under $1M averaged annual revenue over the last three years and not make any products that are injectable, ingestible, or applied around the eye area where it can come in contact with the mucous membranes of the eye, or are products that remain on the body for more than 24 hours and have to be removed by a professional.
If you fall under a category where you are exempt, you still can register your facility if you want to, and you can list your products if you want to, but it is not required.
It will be interesting to see how these numbers change over the coming years. It will give us a good feel for the number of facilities that are out there and the number of products that are out there. At some point the FDA may make the more detailed information available, as they did with the Voluntary Cosmetic Registration Program.
If you’d like to learn more about the requirements of MoCRA, get tthe 4th Edition of my book “Soap and Cosmetic Labeling.” (updated February 2025).
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