Your products must meet cosmetic labelling regulations i.e. Federal Food, Drug, and Cosmetic Act and Fair Packaging and Labeling Act in USA. As per MoCRA, the Responsible Person's name must appear on the label. The responsible person can be the manufacturer, packager, labeler or another third party agency associated with the cosmetic.
Each cosmetic product must be listed with the FDA providing details about the cosmetic to be sold in the United States including all variants. If there are changes to details of the product these must be updated as soon as possible otherwise, as a best practice, an annual check of product listings should be conducted annually. Enforcement of cosmetic product listings will begin July 1, 2024.
Manufacturers of cosmetics must be registered with the FDA whether they are located domestically (within the United States) or abroad. For foreign (non-US) facilities, a US Agent must be linked with the facility upon registration. Facility registration renewal must occur every 2 years on the odd numbered year. Enforcement of facility registration will begin July 1, 2024.
The safety of the cosmetic and all its ingredients must be substantiated. FDA has not provided a guidance document regarding the formatting or type of data required for the safety evidence. However, they have stated that the source of safety data should be from sound and robust and valid scientific data.
The Responsible Person is a person or an entity (such as a manufacturer, packager, labeler or some other third party agency) that is responsible for the safety of the cosmetic and other obligations including submitting adverse event reaction report to FDA, maintain safety substantiation data, product listing submission and record maintenance and recall coordination. The responsible person does not have to be in the United States.