MoCRA Cosmetic Product Listing Update
Under MoCRA, the Responsible Person for each cosmetic product must confirm each listing annually. LMG handles complete cosmetic product listing submissions including annual updates.
Cosmetic Product Listing Services
A cosmetic product listing isn’t a one-time filing. Under the FDA’s Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the Responsible Person must confirm each listing annually, on the anniversary of the original submission, and must report certain changes within 60 days of the change occurring.
Missing an update deadline doesn’t just create a paperwork gap — an inaccurate or lapsed listing can flag your product during an FDA review and complicate distribution through retailers and marketplaces that check listing status.
Key Requirements for Updating Your Cosmetic Product Listing
MoCRA draws a firm line between what counts as an “update” to an existing listing and what requires a brand-new listing. Getting this wrong is the most common reason a submission gets rejected or delayed.
- Annual Confirmation:Â Even with no changes, the listing must be reconfirmed with FDA each year on the anniversary of your original submission date.
- 60-Day Change Reporting: Updatable details — such as packaging size, distribution status, or contact information — must be reported to FDA within 60 days of the change.
- Discontinued Products:Â If a listed product is no longer marketed, that status must also be reported to FDA within 60 days.
- New Listing Triggers: A change to the product name, formula, product category, or Responsible Person cannot be filed as an update — it requires an entirely new listing.
LMG tracks your listing’s anniversary date, identifies which changes require an update versus a new listing, and submits both through the FDA’s Cosmetics Direct portal on your behalf.
Annual Listing Confirmation
Preparation and submission of your yearly listing confirmation ahead of your anniversary date, so your listing never lapses.
Learn More
Discontinued Product Notification
Filing the required 60-day notice when a listed product is no longer marketed, closing out the listing correctly.
Learn More
Responsible Person Update
Guidance on when a change of manufacturer, packer, or distributor requires a new listing, and preparation of that filing.
Learn More
Formulation Change Re-Listing
A changed formula, fragrance, or color cannot be updated — we prepare the new listing your reformulated product requires.
Learn More
How It Works
Frequently Asked Questions
What happens if I miss my annual listing anniversary date?
The listing is considered lapsed until it’s reconfirmed. FDA does not send a reminder before the deadline, so a missed anniversary date is the most common way a cosmetic listing falls out of compliance. LMG tracks this date for you and files the confirmation before it’s due.
Is an annual update the same as filing a new listing?
No. An annual update simply reconfirms that the listing on file is still accurate. If the product name, formula, category, or Responsible Person has changed, that isn’t an update — FDA requires an entirely new listing instead.
Do I need to report a product that's been discontinued?
Yes. A discontinued product must be reported to FDA within 60 days of the product no longer being marketed, even though the original listing itself doesn’t need to be deleted.
What if my product's packaging size or contact information changes?
These are updatable details. Changes like this must be reported to FDA within 60 days, but they don’t require filing a brand-new listing the way a formula or Responsible Person change would.
Ready to Update Your Cosmetic Products?
LMG handles complete MoCRA product listing preparation and annual update management.
Get Started View Fees