If you sell soap, bath bombs, body butter, or any other personal care product in the U.S., 2026 is a year to pay close attention to what's happening at the FDA. The Modernization of Cosmetics Regulation Act (MoCRA), signed into law back in December 2022, is still working its way through implementation — and this year brings some of the most important deadlines and milestones yet.
At The Lavish Goat, we know how confusing regulatory updates can be, especially for small and independent bath & body businesses that don't have a compliance department on staff. So let's break down what's actually happening in 2026, what's still pending, and what you should be doing right now to stay ahead of it.
MoCRA, Quick Recap
MoCRA is the biggest change to U.S. cosmetics law since the Federal Food, Drug, and Cosmetic Act was passed in 1938. It gave the FDA real enforcement authority over cosmetics for the first time — including the power to mandate recalls, require facility registration, and demand safety documentation. Since 2022, the FDA has been rolling out MoCRA's requirements in phases, and several of those phases are hitting home in 2026.
1. Facility Registration Renewals Are Due Now
This is the most immediate, non-negotiable item on the list. If your business (or your co-packer or contract manufacturer) registered a facility with the FDA by the original July 1, 2024 deadline, that registration is due for its first biennial renewal in 2026. The exact date depends on when you originally registered — renewal is due two years from your initial registration date, not a single industry-wide deadline.
For many bath & body brands that registered right at the deadline, that means a renewal due by July 1, 2026. If you registered earlier in 2024, your renewal window may already be here or even passed.
This matters because products manufactured at an unregistered or improperly renewed facility can legally be considered misbranded or adulterated. That's not a slap on the wrist — it can mean import holds, retail partners pulling your products, or worse. If you haven't checked your registration status through Cosmetics Direct recently, this should be at the top of your to-do list.
What to do: Pull up your original registration confirmation, note the date, and mark your renewal deadline. If you work with a contract manufacturer, confirm they've renewed too — their registration status affects your products.
2. Fragrance Allergen Labeling Is Coming (But Not Quite Yet)
This is the change bath & body retailers are asking about most, and understandably so — fragrance is often the heart of the product. Under MoCRA, the FDA is required to identify specific fragrance allergens that must be disclosed individually on labels, rather than lumped under the generic word "fragrance" or "parfum."
Here's the honest state of play: the FDA has repeatedly delayed this rule. The original statutory deadline was mid-2024, then it slipped, and the most recent target for even a proposed rule is now expected around May 2026 — with a final rule not likely before 2027, followed by an additional compliance window after that. So no, you don't need to change your labels tomorrow. But this rule is coming, and when it lands, it's expected to require identifying dozens of specific allergenic compounds by name, a significant jump from the roughly two dozen ingredients currently flagged under similar international frameworks.
What to do: Don't wait for the final rule to start preparing. Get a full breakdown of the allergen-relevant compounds in every fragrance and essential oil blend you use from your suppliers now. If you sell into Europe or work with suppliers who also serve EU customers, you may already have much of this documentation, since the EU's expanded allergen list is being phased in on a similar timeline. Getting your ingredient documentation in order now will save you a scramble later.
3. Good Manufacturing Practices (GMP) Remain Unfinished — But Still Expected
MoCRA also directs the FDA to establish formal Good Manufacturing Practice regulations for cosmetics. That statutory deadline passed without a final rule, and GMP rulemaking has effectively been pushed to FDA's long-term agenda, with no firm new date announced.
That doesn't mean manufacturing standards don't matter right now. The FDA has signaled it expects cosmetic manufacturers to already be operating with structured quality controls, documentation, and safety practices, and existing adulteration law remains fully enforceable in the meantime. Many in the industry expect the eventual GMP rule to closely mirror ISO 22716, the international cosmetics manufacturing standard.
What to do: If you manufacture your own products, consider benchmarking your practices against ISO 22716 now rather than waiting for a final rule. If you use a contract manufacturer, ask whether they hold ISO 22716 certification or an equivalent — retailers are increasingly asking for this regardless of what the FDA has finalized.
4. Talc and Asbestos Testing Standards
If any of your products contain talc — common in some powders, dry shampoos, or setting products — keep an eye on this one. The FDA has been working on standardized testing methods for detecting asbestos in talc-containing cosmetics, with a final rule targeted for early-to-mid 2026 after an earlier proposed version was withdrawn and revised.
What to do: If talc is part of your formulations, confirm with your supplier what testing protocol they currently use and whether it aligns with where the FDA's standard appears to be heading.
5. Formaldehyde Restrictions in Hair-Smoothing Products
While this is more relevant to hair care than bath & body specifically, it's part of the same MoCRA wave and worth knowing about if your product line crosses into hair treatments. The FDA has been developing a rule to restrict formaldehyde and formaldehyde-releasing chemicals in hair-smoothing and straightening products.
6. Mandatory Recall Authority
One update that applies broadly: the FDA issued draft guidance in late 2025 clarifying how it will decide when to invoke its mandatory recall authority under MoCRA, and what it expects from companies during that process. This is a good prompt to revisit your own internal recall plan, even if you've never had to use one — having documented procedures in place is part of demonstrating good-faith compliance.
The Bottom Line for Bath & Body Retailers
Nothing here requires you to relabel your products overnight. But 2026 is very much a "get your house in order" year:
- Confirm your facility registration renewal date and don't let it lapse.
- Start documenting fragrance allergen data for every blend you use, even though the final labeling rule is still a ways off.
- Benchmark your manufacturing practices against ISO 22716, since GMP rules are coming even if the timeline is unclear.
- Check your talc-containing products against emerging testing standards if applicable.
- Have a written recall plan, even a simple one, ready to go.
Regulatory changes can feel overwhelming, especially for small-batch and handmade bath & body businesses. But staying a step ahead of these requirements isn't just about avoiding penalties — it's part of building the kind of trust that keeps customers coming back to brands like The Lavish Goat. Transparency about what's in our products, and how carefully we make them, has always been part of the promise. These regulatory shifts just make that promise official.
