Cannabis Cosmetics: New Regulations for CBD and Hemp-derived Products
Table of Contents
- Overview of Regulations
- Implications for the Cannabis Cosmetics Market
- Major Changes in the Cosmetics Industry
- Understanding MOCRA and Its Requirements
- Compliance for Cosmetics with CBD or Hemp-derived Cannabinoids
- Impact on State-Licensed Marijuana Manufacturers
Overview of Regulations
The cannabis industry must closely monitor the FDA and state marijuana and hemp laws as they adapt to the “Modernization of Cosmetics Regulation Act of 2022” (MOCRA). This significant legislation updates cosmetic regulations, addressing safety, labeling, adverse event reporting, facility registration, and good manufacturing practices.
Implications for the Cannabis Cosmetics Market
With MOCRA’s enforcement, cosmetic companies must now prioritize safety testing, register facilities, follow good manufacturing practices, and report adverse events. The legislation empowers the FDA with authority for mandatory recalls, ensuring consumer protection.
Major Changes in the Cosmetics Industry
Prior to MOCRA, cosmetic products were not required to undergo safety testing, facility registration, or adhere to GMP regulations. The legislation fills these gaps and enhances FDA oversight, enabling better product control and ensuring consumer safety.
Understanding MOCRA and Its Requirements
MOCRA necessitates “adequate substantiation of safety” for cosmetics, mandating responsible persons to maintain records supporting product safety. The legislation also introduces new labeling requirements, record keeping, and FDA reporting of serious adverse events.
Compliance for Cosmetics with CBD or Hemp-derived Cannabinoids
Cosmetic companies marketing products with CBD or other cannabinoids must comply with MOCRA. This includes registration, good manufacturing practices, recalls, adverse event reporting, and safety substantiation. MOCRA preempts state laws for these specific items.
Impact on State-Licensed Marijuana Manufacturers
Although marijuana topicals do not fall under cosmetics regulations, states with marijuana programs might adopt some MOCRA provisions for marijuana-based topical products. Facility registration and product listing may be subject to state requirements consistent with MOCRA.







