The U.S. Food and Drug Administration ("FDA") released a draft guidance document in January 2026 titled "FDA Records Access Authority for Cosmetic Products: Guidance for Industry" (the “Draft Guidance”). The Draft Guidance...more
Perkins Coie is pleased to publish its Q4 Food and CPG Legal Trends Report. This report is a bite-size version of our annual year in review, providing timely insights on trends. In the fourth quarter of 2025, the Consumer...more
The U.S. Food and Drug Administration (FDA) has issued a draft guidance reminding the cosmetics industry that the agency can access a variety of business records during an inspection of a product’s responsible person and...more
Per- and polyfluoroalkyl substances (PFAS) are used as intentionally added ingredients in some cosmetic formulations, primarily on account of their water- and oil-resistance and long-lasting properties, for conditioning and...more
On January 21, the US Food and Drug Administration (FDA) issued a draft guidance clarifying the agency’s authority to access and copy records related to cosmetic products under the Modernization of Cosmetics Regulation Act of...more
In 2022, the Modernization of Cosmetics Regulations Act of 2022 (MoCRA) was signed into law, bringing about the largest expansion of the U.S. Food and Drug Administration's (FDA) authority to regulate cosmetics since passage...more
Recently, the Food and Drug Administration (FDA) released its “Report on the Use of PFAS in Cosmetic Products and Associated Risks”, evaluating per- and polyfluoroalkyl substances (PFAS) and their use in cosmetic products....more
Assuming the title of this article prompted you to read on, it probably comes as no surprise to you that consumers' interest in the safety and quality of their skincare, fragrance and related personal care products is at an...more
Key Takeaways - FDA delivered its first assessment of PFAS in cosmetics. Issued on December 29, 2025, the statutory deadline under MoCRA, the report is the first federal assessment of PFAS in cosmetic products and establishes...more
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) is considered the most significant expansion of the U.S. Food and Drug Administration’s (FDA) authority to regulate cosmetics since the enactment of the Food, Drug...more
On December 29, 2025, the US Food and Drug Administration (FDA) published its Report on the Use of PFAS in Cosmetic Products and Associated Risks (Report). The Report, as required under the Modernization of Cosmetics...more
The U.S. Food and Drug Administration recently released a report on its evaluation of PFAS in cosmetic products, concluding insufficient data to make a determination on safety....more
FDA has released its report evaluating the safety of PFAS intentionally added to cosmetic products, as mandated by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA)....more
Last month, the US Food and Drug Administration (FDA) issued a draft guidance explaining how it intends to implement the mandatory recall authority established under the Modernization of Cosmetics Regulation Act of 2022...more
As required under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), on December 29, 2025, the U.S. Food and Drug Administration (FDA) published a Report on the Use of PFAS in Cosmetic Products and Associated...more
The U.S. Food and Drug Administration (FDA, or the Agency) published a draft guidance explaining its mandatory recall authority for cosmetic products on December 18, 2025 (90 FR 59129). Entitled “Questions and Answers...more
As year-end cosmetic compliance obligations approach, cosmetic companies should review their annual cosmetic product registration and listing requirements. Cosmetic facility registration renewals are biennial and are not tied...more
What does FDA's new guidance do? The enactment of the Modernization of Cosmetics Regulation Act (MoCRA) in 2022 provided FDA with the clear authority to mandate cosmetic recalls. Accordingly, FDA may order a recall when it...more
The US Food and Drug Administration (FDA) has withdrawn its proposed rule on standardized testing methods for detecting and identifying asbestos in talc-containing cosmetics, almost exactly one year after publication....more
On November 28, 2025, the U.S. Food and Drug Administration (FDA) withdrew its 2024 proposed rule entitled “Testing Methods for Detecting and Identifying Asbestos in Talc-Containing Cosmetic Products.” 90 FR 54603. The...more
On November 28, 2025, while most cosmetic companies were promoting their “Black Friday” deals for this year, the FDA quietly issued a Federal Register notice withdrawing the Agency’s previously proposed regulation for...more
On November 28, 2025, the U.S. Food and Drug Administration (FDA) announced the withdrawal of its proposed rule entitled “Testing Methods for Detecting and Identifying Asbestos in Talc-Containing Cosmetic Products—a notable...more
Perkins Coie is pleased to publish its Q3 Food and CPG Legal Trends Report. This report is a bite-size version of our annual year in review, providing timely insights on trends. In the third quarter of 2025, the Consumer...more
The past three years have marked the most significant expansion of cosmetic industry oversight since 1938. The updates below outline key provisions of the Modernization of Cosmetics Regulation Act of 2022 (“MoCRA”) and...more
Last month the Food and Drug Administration (FDA or the Agency) announced the launch of the FDA Adverse Event Reporting System (FAERS) Public Dashboard for Cosmetic Products. This interactive dashboard provides access to...more