EPA Finalizes Rule: TSCA Reporting and Recordkeeping Requirements for PFAS

On September 28, 2023, EPA finalized the rule for Recordkeeping and Reporting Requirements of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA). This rule requires reporting of information on uses, production volume, disposal, exposure, and hazards of PFAS manufactured or imported since January 1, 2011. Reporting will be submitted electronically through [...]

MoCRA FAQs

UPDATE: On 11/09/2023, FDA released a notice that enforcement for product listing and facility registration requirements under MoCRA will be delayed by 6 months, making the new compliance deadline 07/01/2024. This update comes following delays to the release of the Cosmetic Direct platform.  As new cosmetic product regulation compliance deadlines are quickly approaching, SRC Senior [...]

The EPA Non-PRIA Notification Close Out Has Arrived

Effective June 28, 2023, all antimicrobial notifications submitted to the Antimicrobials Division (AD) prior to October 1, 2022 have been closed out by the Environmental Protection Agency (EPA). The Agency announcement, released on June 29, 2023, followed months of discussion between AD and the antimicrobial industry about how to best address the growing backlog of [...]

EPA Triggers Emerging Viral Pathogens Policy for Marburg Virus

In response to recent simultaneous outbreaks of Marburg virus in Tanzania and Equatorial Guinea the United States EPA has engaged the Emerging viral Pathogens Policy (EVP). The Ministry of Health and Social Welfare for Equatorial Guinea first announced the outbreak on February 7, 2023. Since the announcement, 15 cases and 11 deaths have been confirmed [...]

Let’s Get Ready for MoCRA!

What is MoCRA? The Modernization of Cosmetics Regulation Act (MoCRA) of 2022 was signed into law by President Biden on December 29, 2022 as part of the 2023 Consolidated Appropriations Act , H.R. 2617. This Act significantly increases the U.S. Food & Drug Administration (FDA)’s oversight of cosmetic and personal care products from the 1938 [...]

California Legislation for Cosmetic Products

In addition to compliance assistance with the new Food & Drug Administration (FDA) Modernization of Cosmetics Regulation Act (MoCRA) of 2022, SRC offers compliance support for cosmetic ingredient disclosure and reporting requirements for the California Safe Cosmetics Act of 2005 (CSCA) (and the Cosmetic Fragrance and Flavor Ingredient Right to Know Act of 2020 (CFFIRKA) (Senate [...]

FDA Warning Letter Trends for Over-The-Counter Drugs

SRC monitors industry trends through frequent communication with regulating agencies, and review of warning letters and enforcement actions. From our monitoring of FDA Warning Letters, we have noticed some recent trends in FDA enforcement and interpretation of the regulations of over-the-counter drugs. Bob MacDonald, SRC’s VP of Regulatory Services provides a breakdown of these trends. [...]

The Relationship Between California Ingredient Disclosure Requirements and Prop-65 Warnings; It’s Complicated.

Effective January 1, 2023, California’s Cleaning Product Right to Know Act (CPRTKA) requires intentionally added ingredients listed on Proposition 65 to be included in a designated product’s website and label disclosure. The Act allowed manufacturers to withhold from the label and website disclosure, such ingredients until January 1, 2023 (Note: website disclosure of nonfunctional constituents [...]