Industry leaders from the U.S. cosmetics and personal care sector gathered on Capitol Hill last month to reconnect with lawmakers and reinforce key policy priorities. Organized by the Personal Care Products Council (PCPC), the “Back-to-Session” reception brought together more than a dozen companies to spotlight the sector’s regulatory, economic, and scientific agenda as Congress returned from recess.
The event, held on September 10, centered on the reauthorization of the Over-the-Counter Monograph User Fee Act (OMUFA), implementation of MoCRA, expansion of non-animal testing methods, tariff relief, and the need for regulatory consistency.
We spoke to Karin Ross, executive vice president of government affairs at PCPC for deeper insights into the event’s discussions and the organization’s positioning on current legislative issues.
OTC drug reform and FDA sunscreen reviews under the microscope
As Congress looks ahead to the next round of OTC drug user fee negotiations, PCPC is urging lawmakers to keep provisions in the OMUFA reauthorization that would modernize the FDA’s sunscreen review process and open the door to newer testing methods.
“The language is based on the SAFE Sunscreen Standards Act and focuses on expanding non-animal testing methods that the FDA can adopt when reviewing new active ingredients,” Ross told CosmeticsDesign. “We continue to advocate for non-animal testing methods and modern UV filter approval processes for sunscreen safety evaluations, and this language will help modernize the regulatory framework.”
MoCRA rules take shape as companies prep for deadlines
With key rulemakings expected in late 2025 and early 2026, PCPC members are keeping a close watch on how the FDA will roll out remaining requirements under MoCRA. Clarity on timing, scope, and enforcement remains a top concern.
“Our members are closely watching the upcoming fragrance allergen and Good Manufacturing Practices rule and continue to prioritize clear, timely guidance from the FDA to ensure feasible compliance across businesses of all sizes,” Ross said. “We’ve worked to provide our members with the tools and resources necessary to navigate compliance.”
She added that many companies have already completed initial requirements like facility registration and product listing. While no major technical fixes are on the table, Ross said PCPC is “monitoring to ensure the regulatory framework remains clear and workable.”
Momentum builds around non-animal testing legislation
Non-animal testing continues to be a high priority for the industry, with growing support on Capitol Hill for legislation that would formalize its use and expand federal acceptance of new safety assessment tools.
“Our member companies have played a leading role in advancing alternative safety assessment methods,” Ross said. “As regulators and lawmakers consider how to further implement non-animal testing methods, evidentiary standards should be science-based, internationally harmonized where possible, and flexible enough to evolve as new methods are validated.”
She pointed to the Humane Cosmetics Act and OMUFA reauthorization as two immediate opportunities to move the issue forward. “If passed, the HCA would align U.S. regulations with those of other countries that have adopted animal test bans or regulatory frameworks that emphasize the use of non-animal testing methods.”
Tariff relief efforts target essential inputs, not shortcuts
Supply chain pressures remain a concern for many beauty manufacturers, particularly when it comes to tariffs on specialized ingredients and packaging not readily available in the U.S. PCPC is asking lawmakers to zero in on narrowly targeted relief to protect jobs and preserve domestic operations.
“We are currently engaging with policymakers on this matter to ensure U.S. manufacturers remain competitive, continue producing in the U.S., and protect the jobs and innovation our industry supports,” Ross said.
PCPC is also pushing for more recognition of the U.S.-Mexico-Canada Agreement (USMCA) as a model for future trade deals. “More importantly, USMCA is the only U.S. trade agreement that establishes commitments on good regulatory practices for cosmetics —including the Cosmetic Annex, which has delivered meaningful benefits to our industry.”
In 2024, cross-border cosmetics trade in North America surpassed $10 billion. “U.S. exports to Canada and Mexico, valued at nearly $6 billion, now surpass combined exports to China and Europe,” Ross said.
State-level bans complicate MoCRA’s unified framework
As states continue to introduce ingredient bans and new labeling rules, companies are raising concerns that a patchwork of conflicting policies could undermine federal law and disrupt compliance efforts.
“Based on the latest data, we support 4.6 million jobs, generate $308.7 billion in GDP, and contribute $82.3 billion in tax revenue,” Ross said. “With manufacturing operations in nearly every state, our industry generated $68 billion in U.S. output in 2022 and has consistently delivered a trade surplus for nearly three decades.”
She emphasized that MoCRA was meant to be a unified, science-based framework. “However, state-level ingredient bans, and other regulatory requirements often create a complicated patchwork of conflicting rules that undermine federal law,” Ross said. “That is why we emphasize the importance of MoCRA and the critical role of the FDA.”
