January 31, 2025
Introduction: What the 2025 Regulatory Freeze Means for the Cosmetic Industry
A new presidential administration often brings regulatory shifts, and in 2025, President Donald Trump issued a Regulatory Freeze Pending Review. This memorandum affects all federal agencies, including the Food and Drug Administration (FDA), potentially delaying key MoCRA cosmetic regulations.
What Is the Regulatory Freeze and How Does It Work?
A regulatory freeze pauses any new or pending rules until they undergo further review by new agency leadership. In this case, it applies to:
New proposed rules (not yet finalized)
Finalized rules that have not yet taken effect
Guidance documents related to regulatory enforcement
For the cosmetic industry, this could mean significant delays in the implementation of new MoCRA requirements that were set to take effect.
Which FDA Cosmetic Regulations Could Be Delayed?
Several important regulations under MoCRA (Modernization of Cosmetics Regulation Act) were in progress, including:
Fragrance Allergen Labeling – A rule that would require disclosure of certain fragrance allergens in cosmetic products.
Talc-Containing Cosmetic Testing – The FDA’s new standardized testing methods for detecting asbestos contamination in talc-based products.
Good Manufacturing Practices (GMP) for Cosmetics – The FDA was developing formal GMP regulations to ensure the safety and consistency of cosmetic production.
These proposed rules were at various stages of development, but due to the regulatory freeze, their finalization may now be postponed.
How the Hiring Freeze May Further Impact the FDA
In addition to the regulatory freeze, President Trump implemented a hiring freeze for federal civilian employees, including the FDA. This means:
Open positions at the FDA cannot be filled.
No new positions can be created unless an exemption is granted.
The Office of Management and Budget (OMB) must develop a workforce reduction plan.
This hiring freeze is particularly concerning for the cosmetic industry, as the FDA has already cited limited manpower as a reason for past delays in MoCRA implementation. A smaller workforce could further slow regulatory reviews and enforcement actions.
What This Means for Cosmetic Manufacturers and Brands
For cosmetic brands and manufacturers, these delays create uncertainty. Companies preparing for upcoming FDA requirements may now face shifting timelines. While some may welcome additional time for compliance, others could struggle with uncertainty as to when specific regulations will take effect.
How to Stay Prepared Amid Regulatory Uncertainty
While the timeline for these rules remains uncertain, cosmetic brands should:
Stay updated on FDA announcements regarding MoCRA regulations.
Continue implementing Good Manufacturing Practices (GMP) proactively.
Monitor ingredient transparency requirements, particularly for fragrance allergens.
Work with regulatory consultants to ensure compliance with existing laws.
Conclusion: The Road Ahead for FDA Cosmetic Regulations
The 2025 regulatory freeze will likely delay several anticipated FDA cosmetic regulations under MoCRA. With additional constraints from the federal hiring freeze, the FDA may take longer to implement and enforce new rules. However, businesses can stay ahead by proactively adopting best practices and staying informed on upcoming changes. Further Readings: https://www.whitehouse.gov/presidential-actions/2025/01/regulatory-freeze-pending-review/
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