Are you ready for MoCRA?
Federal regulations are changing and new geographic restrictions are emerging state by state across the country. Do you have a compliance system in place? Have you registered your products? How will you communicate to spa partners that you are compliant?
New MoCRA Laws Add Pressure To Spa Operators
Spas are taking a closer look at safety and compliance.
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA)
Exciting news for the skincare and cosmetic industry: The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is set to reshape FDA oversight.
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is the most significant expansion of FDA’s authority to regulate cosmetics since the Federal Food, Drug, and Cosmetic (FD&C) Act was passed in 1938. This new law will help ensure the safety of cosmetic products many consumers use daily.
Key Changes under MoCRA:
- Facility Registration: All cosmetic facilities must register with the FDA. Renewal is required every two years.
- Product Listing: Listing each cosmetic product with the FDA is mandatory, with updates required annually.
- Adverse Event Reporting: FDA access to adverse event reports is expanded, and reporting requirements are intensified.
- Safety Substantiation: Records supporting safety claims for cosmetic products must be maintained.
- Labeling Requirements: Professional-use cosmetics must be labeled as such. Contact info for adverse event reports is mandatory by Dec. 29, 2024.
- GMP Requirements: Mandatory Good Manufacturing Practice (GMP) requirements will be established by Dec. 29, 2025.
- Enforcement: FDA’s authority to enforce compliance, including mandatory recalls and facility registration suspension, is significantly expanded.
With the new MoCRA regulations from the US Food and Drug Administration, the United States is finally aligning more closely with the stricter EU safety standards for skincare and cosmetics. However, numerous exemptions and loopholes still apply to skincare and cosmetic brands that are not yet required to register under this new law. Consequently, spa operators must continue to screen all existing and potential product partners for safety and geographic compliance.
In the capacity of a spa operator, it is imperative to uphold compliance with both federal and local regulations for all products utilized or offered for sale within the establishment. The MoCRA law plays a significant role in spa operations by stipulating that products may be subject to recall or penalty if they are deemed unsafe or fail to meet geographic compliance standards. As a spa operator, staying informed and ensuring brand partners are adhering to MoCRA regulations is crucial.
To mitigate risks, spa operators should proactively ensure that all products used or offered for sale meet compliance standards. Regularly update staff on regulatory requirements, conduct thorough product assessments, and promptly address any issues that may arise. By prioritizing compliance and transparency, spa operators can minimize the potential financial and trust-related impacts to their business.
Using the Good Face Professional Portal, spas quickly screen both current and potential brand partners to ensure safety and compliance. This extra assurance fosters stronger relationships, establishes trust, and safeguards against misunderstandings related to evolving local regulations or changes in product portfolios.
The Good Face Professional Portal
Product Formulas Benchmarked
Scientific Research Sources Analyzed
Become a Best-in-Class Partner to Spas
Thanks to our collaboration with The Good Face Project, Reason and Remedy brand partners can benefit from reduced rates to access this robust tool. With the basic subscription discounted from $7,500 down to $4,000/year. Submit up to 50 formulas and share them with an unlimited number of spas annually.
MoCRA Compliance Assistance
If you’re a Reason and Remedy brand partner with an active Good Face Project subscription and need to register your products under the new MoCRA law, we can handle that time-consuming process for you for only $100 per formula.
Your sales team can trust that any changes to formulations or updates in local regulations will be clearly communicated to your Spa Partners through the Good Face Professional portal during their routine audits.
Trust And Transparency
Provide an elevated level of trust to spa partners, knowing they have instant access to screen your most recent formulations against the latest scientific research, regulatory policies, and competitive benchmarks.
Enhance your sales team’s efficiency by simplifying the partner evaluation process, saving countless labor hours. Swiftly pinpoint lucrative collaborations and avoid allocating resources to spa partners that may not align with your objectives.
Updating your formula changes in the Good Face Professional portal ensures that all your spa partners immediately have access to those modifications.
Simple. Fast. Safe.
New Improved Brand Screening Workflow
Our spa partners gain instant access to screen products against the Reason And Remedy Informational Policy. We designed this policy to provide an easy starting point to begin screening products for safety, against ingredients that have fallen out of favor among many spas. Spas and corporate hotel chains have the option to create a their own custom policy over time. While individual products may contain restricted ingredients, we believe that shouldn’t automatically disqualify an entire brand. Given that reformulations are common, the Good Face Professional Portal serves as a simple means to communicate such updates and nuances to current or prospective brand partners.
Reason And Remedy Informational Policy
- Reason to Avoid: Acetates, such as ethyl acetate, may pose health concerns, including irritation and potential respiratory issues. They can also contribute to environmental pollution.
- Reason to Avoid: Animal-derived ingredients can raise ethical concerns related to animal welfare. Additionally, some individuals may have allergies or ethical objections to using products containing animal by-products.
- Reason to Avoid: Cyclic silicones like cyclopentasiloxane can accumulate in the environment and may have negative effects on aquatic life. They are also linked to concerns about bioaccumulation.
- Reason to Avoid: Ethanolamines, including ingredients like DEA, MEA, and TEA, may be associated with skin and eye irritation. Long-term use has been linked to potential health risks.
- Reason to Avoid: Ethoxylated ingredients, created through a chemical process called ethoxylation, can be contaminated with 1,4-dioxane, a known carcinogen. They may also cause skin irritation.
- Reason to Avoid: Formaldehyde is a known carcinogen and can cause skin irritation. It’s commonly found in some skincare products as a preservative.
- Reason to Avoid: For individuals with gluten sensitivity or celiac disease, gluten in skincare products can cause skin irritation or trigger an allergic reaction.
- Reason to Avoid: Heavy metals like lead, mercury, and cadmium can accumulate in the body over time, leading to serious health issues. They may be found as contaminants in skincare products.
- Reason to Avoid: Microbeads, often made of plastic, contribute to environmental pollution as they don’t break down easily and can harm aquatic life. Many countries have banned their use.
- Reason to Avoid: Lead is a toxic metal that can be absorbed through the skin. Exposure to lead in skincare products can lead to serious health issues.
- Reason to Avoid: Linear silicones, like dimethicone, can create a barrier on the skin, potentially leading to clogged pores and acne. They may also have environmental implications.
- Reason to Avoid: Mercury is a toxic element that can cause serious health problems. Mercury-related compounds may be found in certain skincare products as contaminants.
- Reason to Avoid: Nanoparticles can penetrate the skin and potentially have harmful effects on human health. They may also have environmental implications.
- Reason to Avoid: Unsustainable palm oil production contributes to deforestation and habitat destruction, impacting biodiversity. Ethical and environmental concerns surround the use of palm oil in skincare products.
- Reason to Avoid: Parabens, such as methylparaben and propylparaben, are known endocrine disruptors and may be linked to hormonal imbalances. They can also cause skin irritation.
- Reason to Avoid: Some PEGs may be contaminated with 1,4-dioxane and ethylene oxide, both of which are known carcinogens. PEGs can also cause skin irritation.
- Reason to Avoid: PFAs have been associated with various health issues, and certain PFAs may be persistent in the environment. They can potentially accumulate in the body over time.
- Reason to Avoid: Petroleum-derived ingredients, like mineral oil, may clog pores and contribute to acne. There are also concerns about their environmental impact.
- Reason to Avoid: Phthalates are endocrine disruptors and may interfere with hormone function. Some phthalates have been linked to reproductive and developmental issues.
- Reason to Avoid: Some quaternary ammonium compounds, such as benzalkonium chloride, may cause skin irritation and have been associated with certain health concerns.
- Reason to Avoid: Resorcinol can cause skin irritation and may have potential health risks. It’s commonly found in products designed for skin exfoliation.
- Reason to Avoid: Siloxanes can bioaccumulate in the environment and are difficult to break down. There are also concerns about their impact on aquatic ecosystems.
- Reason to Avoid: Styrene-related compounds, like styrene acrylates, may cause skin irritation. There are also environmental concerns associated with their production and disposal.
- Reason to Avoid: Sulfates, such as sodium lauryl sulfate, can strip the skin of natural oils, leading to dryness and irritation. They may also cause allergic reactions in some individuals.
"Spa operators receive numerous new brand submissions every week. Good Face Professional can help your brand establish immediate trust by being transparent and easy to screen. If you're interested in learning more about how to effectively use this powerful sales tool, schedule a brief, no-pressure call."
- Gary Adkins