America's Compulsory Registration System for Cosmetics is Coming. FDA Stopped Using the VCRP System!

On March 27, 2023, the FDA announced that it stopped receiving and processing both paper and electronic submissions to the Voluntary Cosmetic Registration Program (VCRP) and said that the FDA is developing a new system for submitting cosmetic industry facility registrations and product filings which mandated by the Cosmetic Regulatory Modernization Act of 2022 (MoCRA). Additionally, FDA issued draft guidance on cosmetic product facility registrations and product listings on Auguest 7, 2023. For more information please refer to Voluntary Cosmetic Registration Program.

Key points:

1. FDA has stopped processing VCRP submissions.
2. FDA is developing a new system for filing cosmetic facility registrations and product listing.
3. Facility registration and product listing data in the current VCRP will not be transferred to the new system.

VCRP is a voluntary registration program established in 1972. Cosmetic companies can register manufacturers, packers, and submit product information such as ingredients and labels to the FDA for filing. The FDA uses information submitted by companies in the VCRP to monitor and regulate cosmetics in the U.S. market.

Mandatory cosmetics facility registration and product listing are one of the important contents of MoCRA. In response to the high volume of registration and filing submissions required by MoCRA, FDA is creating a new system and will no longer use the current VCRP system or accept new submissions submitted to the VCRP system. Notably, the FDA has made it clear that the data in the current VCRP will not be transferred to the new system under development, which may mean that cosmetic companies registered and filed in the VCRP system will need to resubmit their registration and product listing once the new system is online.

All cosmetics companies circulating in the U.S. market must complete business registration and product filing by December 29, 2023, and companies outside the United States need to appoint a U.S. agent. Proregulations remind cosmetics companies to pay timely attention to the dynamics of the US FDA, prepare data in advance, and submit enterprise registration and product filing promptly after the release of the new FDA system. Proregulaions can provide a full set of compliance services such as FDA regulation consulting, product registration, and product listing. We will continue to pay attention to the relevant developments of cosmetics regulations in the United States, if you have relevant questions to consult, please contact us.

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