Labeling Products for Professional Use
MoCRA: This information is applicable to: All Cosmetic Manufacturers
Under the new MoCRA requirements, any products you make for professional use must have all the same information as any other cosmetic product.1 Before MoCRA, professional products were exempted from the label requirements.
What is a "professional product"?
A professional product is one that is intended to be used by a person who is licensed by an official State authority to practice in the fields of cosmetology, nail care, barbering or esthetics. It doesn't include regular retail products that are used by professionals, only products that are specifically intended to be used only by professionals.2
What has to go on the label?
You must put a statement on the label that the product is only to be used or administered by licensed professionals.3 In the past, "Professional use only" has been sufficient. If/When the FDA issues regulations covering this, they may be more specific in what must be stated on the label.
In addition, all the regularly required label content must be on the label of professional products, including the product identity (what it is), net contents, ingredient declaration, business name and address, and any information needed for safe use.4
When does this go into effect?
This section of MoCRA is in effect now. It went into effect on December 29, 2023.
1 21 USC 364e(c)
2 21 USC 364e(c)(1)
3 21 USC 364e(c)(2)(a)
4 21 USC 364e(c)(2)(b)
