Cosmetic import customs clearance
Cosmetics used to be among the lightest-touch imports. MoCRA changed that, and importers who set up before it are the ones most likely to be caught out.
Licensed U.S. customs brokerage. Customs broker of record; movement coordinated through vetted partners.
Cosmetic import customs clearance covers customs entries for beauty and personal care products. The Modernization of Cosmetics Regulation Act introduced facility registration and product listing obligations that did not previously exist for cosmetics, alongside adverse event reporting and safety substantiation requirements — changing what an importer needs in place before shipping.
Key takeaways
- Facility registration and product listing obligations now apply to cosmetics.
- Safety substantiation records must exist for the product.
- Colour additives remain subject to specific restrictions and in some cases batch certification.
- Products making treatment claims may be regulated as drugs rather than cosmetics.
- Requirements introduced by MoCRA continue to be phased and clarified.
What changed
Cosmetics historically carried lighter pre-market requirements than food or drugs. MoCRA introduced facility registration, product listing, adverse event reporting and safety substantiation obligations. For importers, the practical effect is that a supplier who could previously ship without registration may now need it, and product-level listings may be expected.
This area is still developing, so a position confirmed a year ago is worth reconfirming.
Where cosmetics become drugs
A moisturiser is a cosmetic. A moisturiser claiming to reduce wrinkles by acting on skin structure may be making a drug claim. Sunscreens, anti-dandruff shampoos and acne treatments are commonly regulated as drugs. The claim, not the product type, frequently decides which set of rules applies.
How it works
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01
Product classified
Cosmetic, drug, or both — determined by composition and claims.
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02
Registration and listing confirmed
Facility registration and product listings in place where required.
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03
Ingredients reviewed
Colour additives and restricted substances checked against U.S. rules.
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04
Labelling assessed
Ingredient declaration, claims and required statements.
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05
Entry filed
With product codes and affirmations matched to the actual product.
Common mistakes
- Assuming cosmetics are lightly regulated. That was true before MoCRA.
- Treatment claims on a cosmetic label. They can reclassify the product as a drug.
- Unchecked colour additives. U.S. restrictions differ from other markets.
- No safety substantiation on file. The records are expected to exist.
- Relying on last year's position. Requirements in this area are still settling.
Questions
What is MoCRA?
The Modernization of Cosmetics Regulation Act, which introduced facility registration, product listing, adverse event reporting and safety substantiation requirements for cosmetics. It significantly changed what cosmetic importers need in place.
When is a cosmetic treated as a drug?
When its intended use, usually shown through its claims, is to treat or prevent disease or affect the structure or function of the body. Sunscreens, anti-dandruff shampoos and acne products are commonly in this position.
Do I need my supplier registered?
Facilities manufacturing or processing cosmetics for the U.S. market are generally subject to registration requirements. Verify it rather than assume — the consequence at the border is yours, not the supplier's.
Are colour additives restricted?
Yes. U.S. rules on permitted colour additives differ from other markets, and some require batch certification. Reviewing the formulation before import is worthwhile, particularly for products developed elsewhere.
Related
Tell us what you're importing.
Commodity, origin, port and arrival date is enough to start.