Almost every FDA registration deadline is a shared calendar window. Food facilities renew between October and December in even years. Drug establishments renew between October and December every year. Device establishments do the same and pay a fee for the privilege.
Cosmetic facility registration under MoCRA does not work that way, and the difference is catching firms out.
Two years from your registration date
Section 607(a)(2) of the FD&C Act requires that every person who must register a facility renews that registration biennially. FDA’s own worked example is the clearest statement of what that means in practice: if FDA received your initial registration on 20 February 2024, your renewal is due by 20 February 2026.
There is no shared window. There is no October reminder that applies to the whole industry. Your deadline is a function of a date that, for most firms, is buried in an email confirmation from whoever handled the original submission — often a consultant, sometimes a colleague who has since moved on.
With more than 14,000 cosmetic facilities registered as of early 2026, a substantial number of those two-year anniversaries are now arriving continuously, month by month.
Find your date before you need it
The date you need is the date FDA received your initial registration, not the date you prepared it or the date you were told it was “submitted”. Check:
- Your Cosmetics Direct account, which holds the submission record
- The confirmation FDA issued at the time of the original registration
- If a third party filed on your behalf, ask them for the received date in writing
Put it in a calendar with a reminder ninety days ahead. This is the single most useful thing you can do about MoCRA compliance this quarter.
Renewing early is allowed
FDA permits renewals earlier than the two-year point. That matters more than it sounds. If you hold multiple FDA registrations — a cosmetic facility registration and a drug establishment registration, which is common for sunscreen, anti-dandruff and other OTC-monograph products — you can bring the cosmetic renewal forward and align it with the October–December drug registration window.
One compliance date a year, handled in one sitting, is meaningfully harder to forget than two dates drifting independently.
Abbreviated renewal when nothing has changed
FDA offers an abbreviated renewal for facilities whose registration information has not changed since the last submission, alongside the full biennial renewal for facilities that do have changes to report. Paper submission remains available for firms that cannot use the electronic portal.
Either route is an active submission. As with drug registrations, “nothing has changed” is something you have to tell FDA, not something FDA infers from your silence.
Foreign facilities
If your facility is outside the United States, your registration depends on a current U.S. Agent designation. Confirm it is in place and that your agent’s contact details are current before you begin the renewal, not partway through it.
What to do this month
- Establish the exact date FDA received your initial facility registration
- Add the two-year anniversary to a shared calendar, with a 90-day warning
- Decide whether to align the renewal with your other FDA registration dates
- Confirm your U.S. Agent designation if you are a foreign facility
- Check whether your product listings are current — they are a separate obligation from facility registration
LMG handles MoCRA facility registration, product listing and U.S. Agent representation for cosmetic firms worldwide. See MoCRA Cosmetic Facility Registration or contact our regulatory team.
Related: MoCRA Cosmetic Product Listing · Cosmetics U.S. FDA Agent Service · MoCRA Adverse Event Reporting
Sources: FDA, FDA Updates Web Portal and Informational Materials to Help Cosmetic Facilities Prepare for Biennial Registration Renewal, fda.gov; FD&C Act section 607(a)(2).