Updated October 2026
MoCRA's duties fall on the responsible person, the brand whose name is on the label. A warehouse that stores and ships your sealed goods carries much less, but it matters a great deal on the day you recall a lot.
MoCRA facility registration applies to facilities that manufacture or process cosmetics. The listing, adverse-event and safety duties belong to the responsible person, whose name is on the label. A 3PL that only stores and ships sealed, finished goods is generally not required to register. Our part comes at recall time. We record lot and batch when your stock arrives, so an affected lot can be isolated and traced to the orders it shipped on.
By The Fulfillment.com team
The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) changed how cosmetics are regulated in the US. A common mistake beauty brands make when vetting a fulfillment partner is assuming the partner takes on part of the brand's compliance burden. It doesn't.
MoCRA facility registration applies to facilities that manufacture or process cosmetics. The responsible person is the manufacturer, packer or distributor whose name appears on the label. That company lists its products, reports adverse events and keeps the evidence that each product is safe. A 3PL that only stores and ships sealed, finished goods is generally not a facility required to register. A vendor that calls itself a "MoCRA-registered manufacturer" on your behalf is claiming a position it doesn't hold, and that claim suggests it isn't sure where its responsibilities end and yours begin.
In cosmeceutical fulfillment, the warehouse's part is smaller. Listing, adverse-event reports and safety records stay yours. A good partner makes those duties workable without taking them over, by keeping the record of lots and orders that a recall runs on.
Track by lot as well as by SKU. For a warehouse holding finished goods, MoCRA matters most when a recall comes, and a recall you can trust depends on tracking by lot.
Lot records from the day stock arrives. Our receiving team records lot and batch as each shipment is checked in, and BestOMS, with Deposco behind it, carries them to every order. Reporting a serious adverse event to the FDA is the responsible person's job, on the responsible person's deadline. If that report leads to a recall, the lot record we kept lets you limit the pull to the affected lot. The same record drives how we run lot, expiry, and first-expired, first-out (FEFO) control across the network.
Kitting and relabeling can count as "processing." A warehouse that holds your goods generally doesn't need to register, but there is an exception to state carefully. MoCRA's idea of processing is broader than manufacturing, and a fulfillment center that does custom labeling or certain repackaging may fall under it. Picking, packing and shipping sealed units does not. Putting finished units together into a branded kit comes closer to the line, and applying labels to product can cross it. Where a job lands depends on the exact work. A fulfillment partner should say precisely what kitting and labeling it does instead of calling itself "fully MoCRA compliant."
We put finished, sealed units together into kits and boxes through our kitting and sample assembly work. We don't formulate, fill, compound or relabel raw product. Before you rely on any of this, have counsel confirm where your own kitting program falls.
SPF and other OTC-drug products carry drug requirements as well. Few beauty catalogs are all cosmetics. The FDA regulates some beauty products as OTC drugs under its monographs, SPF sunscreen most commonly, and some count as both a cosmetic and a drug. A moisturizer with an SPF claim is the usual example. It carries drug requirements on top of its cosmetic ones, and in the warehouse it needs handling and labeling kept separate from MoCRA-scope cosmetics.
Every order we ship carries the lot and batch recorded at receiving, and every pick is barcode-scanned before it leaves, as part of our warehousing and receiving work. Storage matters too: heat- and humidity-sensitive actives need the conditions their stability data calls for, so ask any partner what its buildings actually hold.
When a recall instruction comes, the lot record is what keeps it targeted: the affected lot can be isolated and traced to the orders it shipped on. Units that come back go through our returns and reverse logistics process, where each one is inspected and sorted, and a dated unit gets a lot and expiry check before it goes back into sellable stock.
To test any partner's MoCRA claims, ask where its registrant status ends and yours begins. Then ask it to show you how it would isolate one affected lot across your real product mix.
Generally not, if the partner only stores and ships sealed, finished goods. MoCRA facility registration applies to facilities that manufacture or process cosmetics. The listing, adverse-event and safety duties belong to the responsible person, the company whose name is on the label. Be careful with a 3PL that says it is a MoCRA-registered manufacturer on your behalf. A warehouse that holds finished goods isn't in that position.
It makes your recall duties something you can actually carry out. We record lot and batch when your stock arrives and carry them to every order, so an affected lot can be traced to the orders it shipped on. The recall decision stays with you; our job is to pull the units on the lot list you send. Because each lot is tied to its orders, that pull can be limited to one lot instead of a brand-wide withdrawal.
A SKU record only tells you which product is affected. It can't single out the batch. A lot record names the exact production lot, every order that held a unit from it, and the customers who received those orders. With it, you pull one lot. Without it, you may have to withdraw a whole product line. You need this when a recall comes, though MoCRA doesn't spell it out as a requirement for a fulfillment partner.
It can. MoCRA's idea of processing is broader than manufacturing, and custom labeling or certain repackaging may fall under it. Picking, packing and shipping sealed units does not. Putting sealed units together into a branded kit sits somewhere between the two. We kit finished, sealed product, and we don't relabel or fill raw product. Have counsel check your own kitting and labeling program against the processing line.
Not only as a cosmetic. The FDA regulates sunscreens as drugs, and some products count as both a cosmetic and an OTC drug. An SPF moisturizer carries drug requirements on top of its cosmetic ones. In the warehouse, OTC-drug products need handling and labeling kept apart from MoCRA-scope cosmetics, rather than being lumped in with the rest of a beauty catalog.