U.S. Updates Timeline for MoCRA Rulemakings on GMP, Fragrance Allergens, and Asbestos Testing Methods

On September 4, 2025, the Office of Information and Regulatory Affairs (OIRA) released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, outlining federal agencies' intended regulatory activities over the next 12 months. The agenda, while non-binding, provides an important roadmap of upcoming rulemakings

For the cosmetics sector, five regulatory actions are listed, three of which directly relate to the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). Notably, the anticipated publication dates remain targets and may still face further delays.

Proposed Rule	Status and Estimated Time	Summary
Use of Formaldehyde and Formaldehyde-Releasing Chemicals as an Ingredient in Hair Smoothing Products or Hair Straightening Products	Proposed Rule Stage - December 2025	Would ban the use of formaldehyde and formaldehyde-releasing chemicals (e.g., methylene glycol) in hair smoothing or straightening products sold in the U.S. applied with heat.
MoCRA Rules: Disclosure of Fragrance Allergens in Cosmetic Labeling	Proposed Rule Stage - May 2026	Would identify specific substances as fragrance allergens and require their disclosure on cosmetic product labels.
MoCRA Rules: Testing Methods for Detecting and Identifying Asbestos in Talc-Containing Cosmetic Products	Final Rule Stage - March 2026	Would establish standardized testing methods for detecting and identifying asbestos in talc-based cosmetic products.
MoCRA Rules: Good Manufacturing Practice (GMP) for Cosmetic Product Facilities	Long-Term Actions - To Be Determined	Would set out GMP requirements for cosmetic facilities to help ensure product safety.
Amendment of Procedural Requirements for Color Additive Petitions	Long-Term Actions - September 2026	Proposes amendments to modernize procedural requirements for color additive petitions, including data submission, review processes, and regulatory timelines.

Many of these initiatives were previously delayed under the Fall 2024 Unified Agenda, and the updated schedule reflects FDA's gradual rollout of MoCRA implementation. With fragrance allergen labeling and asbestos testing rules now projected for 2026, cosmetic industry stakeholders should closely track developments and prepare for potential compliance obligations.

U.S. Updates Timeline for MoCRA Rulemakings on GMP, Fragrance Allergens, and Asbestos Testing Methods

Further Reading