News & Articles

MoCRA Update: FDA Provides Summary Data on Facility Registrations and Product Listings

The U.S. Food and Drug Administration (FDA) has released summary data from mandatory registration of cosmetic product facilities and listing of cosmetic products under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA).

MoCRA Background & Requirements

MoCRA was passed in 2022 in an effort to modernize and strengthen cosmetic regulations in the United States. MoCRA replaced the previous Cosmetic Act, which had not been updated since 1938.

Subsequent to the bill’s passage, the FDA issued regulations implementing the law. In issuing MoCRA regulations, FDA’s aim was to help ensure the overall safety of cosmetic products, and expand the Agency’s ability to trace and track non-compliant products and facilities.

MoCRA Requirements:

  • FDA registration for cosmetics facilities
  • Product listings for each cosmetic product
  • Adverse event reporting
  • Safety substantiation
  • Compliance with Good Manufacturing Practices (GMPs)
  • Fragrance allergen labeling

MoCRA also gives the FDA new records access and mandatory recall authority.

The FDA has issued guidance providing recommendations to assist companies in complying with the law. In addition, the agency developed a new online tool – Cosmetics Direct – dedicated exclusively to product facility registration and cosmetic product listing submissions.

New Data

As of January 1, 2025, the number of unique, active facility registrations is 9,528 and the number of unique, active product listings is 589,762.

The top five states for number of domestic registered facilities are:

  • California (373)
  • Florida (201)
  • New Jersey (144)
  • Texas (120)
  • New York (118)

The top five countries for foreign registered facilities are:

  • China (4,260)
  • South Korea (617)
  • India […]

Breaking Trade News: New AD/CVD Case, OFAC Alert, FDA

Here is a recap of the latest customs and international trade news:    

Customs and Border Protection (CBP)  

  • Susan S. Thomas was appointed Acting Executive Assistant Commissioner for CBP’s Office of Trade. 
  • CBP modified a withhold release order on Dominican Republic sugar company Central Romana, allowing it to import into the U.S. 
  • CBP added a target deployment of September 2025 for when the agency expects to implement Stage 3 of an enhancement aimed at withholding in ACE the release of de minimis shipments that exceed the $800 per person/per day threshold. 
  • CBP officers at an Indianapolis express consignment facility seized four packages of counterfeit Botox vials with an MSRP of $8,500 had the products been real.  

Administration 

  • The Steel Manufacturers Association President Philip K. Bell wrote an op-ed in the Pittsburgh Post-Gazette describing how President Trump’s action to close loopholes and exemptions will strengthen the American steel industry.  

U.S. Department of Commerce 

  • A new Antidumping and Countervailing duty action has been filed against “Polypropylene Corrugated Boxes” imported from Viet Nam and China. […]
By |2025-03-21T16:55:47-04:00March 21, 2025|news, Snapshot|0 Comments

New AD/CVD Case Filed Against Polypropylene Corrugated Boxes from Vietnam and China

A new antidumping and countervailing duty action has been filed against “Polypropylene Corrugated Boxes” imported from Vietnam and China. These boxes are colloquially know as Vegetable or Seafood Boxes and are used to pack and ship articles such as produce. The allegation is that imports from China are both unfairly subsidized and are being dumped (sold below cost) while imports from Vietnam are alleged to being dumped (sold for below cost).

Full list of exporters here.

Background on AD/CVD Investigations

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent.

Scope of the Investigation

The merchandise covered by these investigations is Polypropylene Corrugated Boxes (“PCBs”). PCBs are boxes, totes, or other containers made of corrugated polypropylene sheets, also known as polypropylene hollow core sheets, polypropylene twin wall sheets, or multi wall sheets.

The […]

Breaking Trade News: CBP Monthly Update, 232 Tariffs, Commerce Investigations

Here is a recap of the latest customs and international trade news:    

Customs and Border Protection (CBP)  

  • CBP released the February 2025 monthly update. Highlights: 
    • Identified $2.9 million in duties and fees owed. 
    • Stopped 1,024 shipments for further examination based on the suspected use of forced labor. 
    • Seized 1,815 shipments that contained counterfeit goods.  
  • CBP issued guidance on import duties on imports of steel and steel derivative products. 
  • CBP issued guidance on import duties on imports of aluminum and aluminum derivative products. 
  • CBP released it’s April trade outreach webinar schedule.  
  • CBP officers seized a shipment containing fake designer jewelry worth $3.5 million, had it been genuine.  
  • Baltimore CBP officers seized over $72k in counterfeit vinyl flooring tiles from China.  
  • CBP seized counterfeit skin creams and sharpie pens worth over $30k in Allentown, PA. 

Administration 

By |2025-03-20T21:57:37-04:00March 14, 2025|news, Snapshot|0 Comments

Breaking Trade News: Tariff Guidance, OFAC Sanctions, WTO

Here is a recap of the latest customs and international trade news:

Customs and Border Protection (CBP) 

  • CBP issued guidance on the additional tariffs on imports from Canada and Mexico. 
  • CBP held its quarterly Commercial Customs Operations Advisory Committee (COAC) meeting  in Atlanta where the agency committed to implementing President Trump’s America First trade policy.
  • CBP is implementing a new Chapter 99 harmonized tariff schedule number to implement the increase in duties from 10% to 20% on imports from China.
  • CBP is seeking public comments related to the distribution of funds pursuant to the continued dumping and subsidy offset for affected domestic producers. Comments on the information collection are due May 5.
  • CBP officers seized more than $52,000 in unreported currency during two separate seizures at Washington Dulles International Airport.

Administration 

  • On March 4, new tariffs went into effect on imports from:
    • China: 20%
    • Mexico: 25%
    • Canada: 25%
    • Federal register notices available here (Canada, Mexico,
By |2025-03-20T21:59:49-04:00March 7, 2025|news, Snapshot|0 Comments
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