Compliance

Every material is screened against every US jurisdiction that restricts cosmetic ingredients. The screen is maintained as structured data and re-run on a schedule against the current OEHHA list.

MoCRA — what actually applies to you

FDA's draft guidance on registration and listing excludes from the facility definition establishments that manufacture cosmetic ingredients but not cosmetic products, and MoCRA's product listing attaches to a cosmetic product — a preparation with a qualitatively and quantitatively set composition — rather than to a single raw material. As your ingredient supplier we sit largely outside registration and listing. You, as the responsible person named on the finished label, do not: product listing within 120 days of market entry, annual updates, biennial facility renewal, serious adverse event reporting within 15 business days, and safety substantiation on file. The small-business exemption below $1,000,000 in average annual US cosmetic sales covers registration, listing and GMP, but not adverse event reporting, safety substantiation or labeling — and it is void for products contacting the eye's mucous membrane.

Two edges we do not pretend to have resolved

First, whether a pre-blended base or kit counts as a cosmetic product with a set composition under MoCRA. We have found no FDA guidance that settles the line. Second, whether a raw material sold direct to a consumer who applies it undiluted becomes a cosmetic product by intended use, regardless of B2B framing — the doctrine turns on your marketing copy, which is why every product description on this site says "for use as an ingredient in cosmetic formulations". Both are worth a written opinion from counsel.

The drug-claim line, and why our copy reads the way it does

Cosmetic versus drug turns on intended use, and FDA establishes intended use from explicit claims in labeling and advertising, from consumer perception, and from ingredients with well-known therapeutic properties. Supplier technical literature is full of language that converts a product into an unapproved new drug the moment it appears on a public page: stimulates collagen synthesis, inhibits melanin production, penetrates the dermis, repairs the skin barrier, regenerates cells, anti-inflammatory, heals. FDA has issued warning letters on exactly this basis.

So our public product descriptions stay functional — cationic conditioning emulsifier, C16 fatty alcohol thickener — and mechanism-of-action material from supplier literature sits behind a technical-literature section clearly framed as supplier data for professional formulators. We recommend you structure your own pages the same way. It costs nothing and it is the cheapest regulatory insurance available to a small brand.

This page is a service, not legal advice

We are a raw-material supplier maintaining a screening matrix, not your regulatory counsel. Statutory definitions of cosmetic product vary between states in ways that affect whether an ingredient sale is captured at all, several rulemakings are in flight, and the Proposition 65 titanium dioxide position in particular has been unsettled by litigation. Verify anything you intend to rely on.