The Short Answer: Cosmetics Are Now Regulated More Like Food

For most of a century, the rules governing cosmetics in the United States barely changed. The Federal Food, Drug, and Cosmetic Act of 1938 set the baseline, and it stayed largely untouched while food, drugs, and medical devices all went through major regulatory overhauls. That changed in December 2022, when Congress passed the Modernization of Cosmetics Regulation Act — MoCRA — and it has been phasing into enforcement through 2025 and into 2026. If you've noticed ingredient panels getting longer or more specific lately, this is a big part of why.

Here's what MoCRA actually requires, what it doesn't do, and why full transparency was already the standard for a small, farm-based brand before any of this became law.

What MoCRA Actually Requires

MoCRA is the first major update to federal cosmetics oversight since 1938, and it puts several new obligations on every brand that sells personal care products in the U.S.:

• Facility registration and product listing — manufacturers now have to register their facilities with the FDA and file a listing for every product they make, something that was never required before.
• Safety substantiation — brands must keep documentation showing their products are safe for their intended use, whether that's testing data, published research, or a combination of both.
• Serious adverse event reporting — a serious reaction now has to be reported to the FDA, and as of late 2025 that data is publicly viewable through the FDA's cosmetics adverse event dashboard.
• Manufacturing standards — the FDA is developing Good Manufacturing Practice (GMP) regulations that set minimum standards for how cosmetics are made, processed, and stored.
• Fragrance allergen disclosure — instead of hiding behind the single word "fragrance," labels will eventually have to name specific allergens known to cause reactions.

What MoCRA Does Not Do

It's worth being precise about the limits here, because it's easy to assume a new federal law means more than it does. MoCRA does not create a legal definition for "natural" or "clean" — those remain marketing terms with no regulatory meaning, the same as before. It does not ban specific ingredients outright; ingredient restrictions are handled separately and have existed in a limited form for years. And it does not rate or approve individual formulas the way a food label's Nutrition Facts panel is standardized. MoCRA is a paperwork, accountability, and reporting law — it changes what brands have to prove and disclose, not what they're allowed to put in a bottle.

What This Actually Means for You as a Shopper

The practical upside is visibility. For the first time, there's a public record of serious safety complaints tied to specific cosmetic products, rather than that information staying inside a company or a lawsuit filing. Fragrance labeling should get more specific over time instead of hiding behind one catch-all word. And every registered facility now has to be traceable back to an actual manufacturer.

The thing that hasn't changed: reading the full ingredient list is still the shopper's job. MoCRA doesn't sort ingredients into "good" and "bad" columns, and a product can be fully MoCRA-compliant while still containing ingredients you'd rather avoid. Compliance is a floor, not a quality claim.

Why This Wasn't a Big Shift for a Farm-Based, Small-Batch Brand

A lot of what MoCRA is pushing the whole industry toward — full ingredient transparency, traceability back to where something was actually made, a real paper trail from raw material to finished product — is closer to how Heart Tone Botanicals has operated from the start. A meaningful share of the botanicals in our formulas are grown on our own family farm in Vero Beach, Florida, which means the distance between "where this ingredient came from" and "what's in the jar" is short and well documented, not several layers of unnamed suppliers deep.

We've written before about what that process actually looks like, from harvest to the finished bottle — the same kind of traceability MoCRA is now asking the rest of the industry to formalize.

What to Look For as the Rules Roll Out

As MoCRA continues to phase in, a few habits will separate brands that were already doing this from brands scrambling to catch up:

• A full ingredient list with actual botanical names, not just "fragrance" or "proprietary blend" doing the hiding
• A brand that can tell you where an ingredient was grown or sourced, not just that it's "natural"
• Product pages and labels that don't need to change dramatically once new disclosure rules take effect, because the information was already there
• A willingness to say what a product doesn't contain, in plain language, rather than leaning on a single feel-good word

The Bottom Line

MoCRA is a real, meaningful shift in how the FDA oversees cosmetics — the biggest one in nearly ninety years. But it's a transparency and accountability law, not a seal of approval, and it still leaves the job of reading the ingredient list to you. The upside is that brands built around full disclosure from the beginning don't have much to change.

You can see that approach on any Heart Tone Botanicals label — the Living Crystal Toothpaste and Restorative Mouth Rinse both list every botanical by name, and the Ancient Organic Soap line has always spelled out exactly what went into the batch. Explore the full oral care collection to see the rest of the lineup.