Until recently, the federal law governing cosmetics in the United States was written in 1938. That is not a typo. For most of the modern nail industry’s existence, a company could manufacture and sell gel polish in the US with no facility registration, no product listing, and no obligation to tell anyone if a customer had a serious reaction.
The Modernization of Cosmetics Regulation Act, usually shortened to MoCRA, changed that. If you buy professional nail products, it changed something for you too, because it gave you a new way to tell which brands are operating responsibly.
What MoCRA Is
MoCRA was signed into law at the end of 2022 as part of a larger federal spending bill. It expanded the Food and Drug Administration’s authority over cosmetic products sold in the US, adding requirements for manufacturers and brands around registration, safety records, adverse event reporting, and labeling. Compliance deadlines rolled out through 2024 and 2025.
It is the most significant update to US cosmetics law in more than eighty years.
Why It Was Needed
The beauty market in 2026 looks nothing like the one the 1938 law was written for. A nail tech can order product from a domestic brand, a European brand, or an anonymous marketplace seller in the same afternoon. Reputable manufacturers were already running safety testing and quality controls, but nothing required it, and nothing distinguished them on the shelf from a seller who had done none of it.
MoCRA was designed to raise the floor: improve consumer safety, increase transparency, make manufacturers accountable, and give the FDA the tools to act when something goes wrong.
What MoCRA Requires
For a nail brand selling in the US, the main obligations are:
Facility registration. Any facility that manufactures or processes cosmetics for the US market must register with the FDA and keep that registration current. This applies to foreign facilities too.
Product listing. Brands must submit a listing of each cosmetic product they sell, including ingredients, to the FDA.
Adverse event reporting. Brands must keep records of health complaints and report serious adverse events, such as a reaction requiring medical attention, to the FDA within fifteen business days.
Safety substantiation. Brands must hold adequate evidence that each product is safe when used as directed. They do not have to submit it in advance, but they must be able to produce it.
Labeling. Labels must include a US address, phone number, or electronic contact through which adverse events can be reported. Professional-use products must carry specific language stating they are for licensed professionals.
Good manufacturing practices and records. The FDA gained authority to set GMP standards for cosmetics and to access safety records on request, and it gained mandatory recall authority for the first time.
What It Means When You Are Buying Product
MoCRA is not a quality guarantee. Registration does not mean a product performs well, and the FDA does not pre-approve cosmetics. But it does create a clear line between brands that are participating in the system and brands that are not.
A few practical checks you can make on any brand you are considering:
- Is there a US contact address or phone number on the label? MoCRA requires one.
- Does the brand publish full ingredient lists? Listing them with the FDA is mandatory; publishing them for you is a sign of confidence.
- Can the brand tell you where the product is manufactured? A registered facility is not a secret.
- Does the brand have a way for you to report a reaction? It is required to.
If a seller cannot answer those questions, you are looking at a product that may be operating outside the law, and you have no recourse if something goes wrong at your table.
What It Means for Clients
For the person in your chair, MoCRA mostly works in the background. Its effect is that the products used on them are more likely to come from a manufacturer that keeps safety records, monitors complaints, and can be compelled to recall a product that causes harm. If a client ever asks whether nail products are regulated, the honest answer is now “yes, since 2023, and here is what that means.”
The Bottom Line
MoCRA is not the most exciting topic in nails. It is one of the most useful. It gives you a short list of questions that separate a responsible brand from a mystery bottle, and it gives you leverage you did not have before: a legal framework behind every product you put on a client.
Written by the Syren Cosmetics team. This article is a general overview of MoCRA as of September 2026 and is not legal advice.