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Category: Cosmetics

MoCRA in 2026

09/26/2026

Registration Is Only the Beginning

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) significantly expanded FDA’s authority over cosmetics and created new obligations for many cosmetic companies. For businesses that entered the market after MoCRA’s enactment, one of the most common misconceptions is that facility registration and product listing equal FDA approval. They do not. FDA recently reiterated that […]

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Your Website Is an FDA Compliance Issue

09/25/2026

When Marketing Becomes Regulation

For many consumer brands, the package receives careful legal review while the website is treated as “marketing.” From an FDA perspective, that distinction can be dangerous. FDA evaluates representations made about regulated products when determining issues such as intended use, product classification, labeling , and whether a product is being marketed in violation of the […]

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Before You Launch

09/25/2026

15 FDA Questions Every Consumer Brand Should Answer

Launching an FDA-regulated consumer product involves considerably more than creating a formula, designing packaging, and placing an order with a manufacturer. Food, beverage, dietary supplement , and cosmetic companies can encounter regulatory issues involving ingredients, product classification, labeling, claims, manufacturing, registration, safety substantiation, and post-market obligations. The most expensive regulatory problems are often those discovered […]

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FDA Midyear 2026 Review

08/06/2026

7 Regulatory Changes Every Regulated Company Should Be Tracking

The first half of 2026 was anything but quiet at the U.S. Food and Drug Administration. While many companies expected a slower regulatory environment amid broader federal government changes, FDA instead continued advancing significant initiatives affecting foods, beverages, dietary supplements, cosmetics, OTC drugs, and medical devices. The agency’s focus has increasingly shifted toward data-driven oversight, […]

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FDA Import Detentions, Refusals, and Import Alerts

06/04/2026

A Practical Enforcement Continuum

FDA import enforcement operates along a predictable—but unforgiving—continuum: detention, refusal, and, in repeat cases, import alert placement. Recent FDA data dashboards confirm sustained levels of import refusals and enforcement activity, reflecting the Agency’s continued reliance on data-driven screening and historical compliance patterns. For importers, the practical issue is not whether this framework exists—but whether entries […]

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One Day, Big Impact

05/27/2026

FDA’s New Inspection Playbook (and Why You Should Care)

The U.S. Food and Drug Administration has officially entered its “speed dating” era—at least when it comes to inspections. On May 6, 2026, FDA announced a pilot program for one-day inspectional assessments, a shorter, risk-based alternative designed to complement traditional, multi-day inspections. While the concept sounds deceptively simple—“we’ll be in and out in a day”—the […]

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MoCRA in Practice

05/05/2026

How FDA Is Implementing Its Expanded Cosmetics Authority—and What It Means for Industry

The Modernization of Cosmetics Regulation Act of 2022 (MoCRA) represents the most consequential update to U.S. cosmetics regulation since the Federal Food, Drug, and Cosmetic Act was enacted in 1938. In a recent FDA Voices article, the U.S. Food and Drug Administration explains how it is implementing this new authority and why these changes materially […]

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Liquidated Damages for FDA‑Regulated Products

04/20/2026

What They Are, How to Avoid Them, and How to Mitigate Successfully

Importing FDA‑regulated products is a bit like going through airport security: most of the time it’s routine, but if something goes missing—or looks suspicious—you may be pulled aside, detained, and asked uncomfortable questions. In the import world, that “secondary screening” can result in liquidated damages (and potentially greater scrutiny) if an importer fails to comply […]

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FDA’s PFAS Cosmetics Report

04/14/2026

Forever Chemicals, Federal Oversight, and the Changing Regulatory Landscape

The beauty industry has long been a proving ground for scientific innovation. But lately, it has also become a focal point for regulatory scrutiny—particularly when it comes to per- and polyfluoroalkyl substances (PFAS), the class of chemicals often referred to as “forever chemicals.” PFAS have drawn increasing attention from regulators, lawmakers, and consumer advocates due […]

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FDA Launches Unified Adverse Event Monitoring System (AEMS), Expanding Safety Surveillance and Regulatory Oversight

03/24/2026

On March 11, 2026, the U.S. Food and Drug Administration (FDA) announced the launch of the Adverse Event Monitoring System (AEMS), a centralized, AI-driven platform that modernizes the agency’s post-market safety surveillance framework across all regulated product categories. These include medical products, vaccines, medical devices, tobacco products, food, cosmetics, and veterinary medicines. AEMS represents a […]

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★★★★★

Working with Shelly on various new product launches over the last couple of years has been seamless. Quick and clear guidance is always what we get.
R.G. Client
I've been working with Shelly and her team at Garg law for a little while now and they are fantastic! Very responsive, professional and they certainly get things done. Extremely satisfied with their service and highly recommend.
Mike H. Client
Ms Garg helped my company navigate an FDA import issue. She achieved an excellent result, was very responsive and professional, and managed to keep the project within budget. She is a stellar attorney.
Dr. Sastry Client
I have been using Shelly Garg as FDA Counsel for 10+ years, since she was at another international law firm. While we continued to use the previous firm she was at (mainly due to the process required to change firms), we realized the quality of counsel was not the same. We have since been using Garg Law and the ease of use and trust in the knowledge was back instantly. Shelly has the skills to help me understand the regulations (by translating into layman's terms) and risks in a manner that is specific to my business. She is also extremely timely in her responses which is critical when we have a deadline mandated by the FDA. Many other attorneys cite the regulations which l've already read, but need further counsel. In my opinion, this demonstrates Shelly's in-depth knowledge of the regulations, how they pertain to the law, and how they are applicable IRL. Shelly's personable approach and pleasant manner in communication makes it very easy to have been work with her and have productive discussions on the best next steps. She truly has a passion iternational for all things FDA and I've learned so much from her.
Claire P. Client

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