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Loeb & Loeb Regulatory partner Kristen Klesh appeared as a guest on “Suited with Kenya Wiley,” a podcast covering key legal and political issues impacting the fashion industry.
In the episode, Kristen discussed the business of beauty and the law—from cosmetic ingredient and manufacturing regulation to supply chain and packaging compliance—covering both the Modernization of Cosmetics Regulation Act (MoCRA) and California’s Toxic-Free Cosmetic Act.
“MoCRA is largely designed to bring cosmetics under the same umbrella type framework as other FDA-regulated products, which I think everyone can align on,” she said in the podcast. “And so in doing that, there’s probably a dozen substantive provisions that Congress implemented under MoCRA and wanted FDA [Food & Drug Administration] to issue regulations to enact.” Kristen noted that there are five or six key provisions brands should focus on now.
Kristen also discussed the California Toxic-Free Cosmetic Act, which she noted was “actually passed back in 2020, but went into effect as of January of this year. And essentially it prohibits the manufacturer’s sale, delivery or holding of a cosmetic product that has intentionally added, which means if it's contamination, maybe there's some sort of wiggle room, but you cannot proactively add broad terms.”
Click here to listen to the episode from the “Suited with Kenya Wiley” podcast.
In the episode, Kristen discussed the business of beauty and the law—from cosmetic ingredient and manufacturing regulation to supply chain and packaging compliance—covering both the Modernization of Cosmetics Regulation Act (MoCRA) and California’s Toxic-Free Cosmetic Act.
“MoCRA is largely designed to bring cosmetics under the same umbrella type framework as other FDA-regulated products, which I think everyone can align on,” she said in the podcast. “And so in doing that, there’s probably a dozen substantive provisions that Congress implemented under MoCRA and wanted FDA [Food & Drug Administration] to issue regulations to enact.” Kristen noted that there are five or six key provisions brands should focus on now.
Kristen also discussed the California Toxic-Free Cosmetic Act, which she noted was “actually passed back in 2020, but went into effect as of January of this year. And essentially it prohibits the manufacturer’s sale, delivery or holding of a cosmetic product that has intentionally added, which means if it's contamination, maybe there's some sort of wiggle room, but you cannot proactively add broad terms.”
Click here to listen to the episode from the “Suited with Kenya Wiley” podcast.
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