# FDA Issues Cosmetic Recall Guidance

The FDA issued final guidance explaining how it may order mandatory recalls of cosmetics under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA); the guidance makes no substantive changes from the draft. Cosmetic manufacturers, packers, and distributors identified on a product label as the responsible person should understand their role in a recall, including how to respond to a written FDA offer and a possible 10-day hearing. Although this is not a government procurement rule, it has implications for suppliers and the agreements that govern cosmetic product recalls and related costs.

- Companies supplying cosmetic products should review how their supply and distribution agreements assign recall responsibilities, notification duties, and costs.
- Responsible persons should check that safety and labeling controls, adverse-event monitoring, and procedures for responding to FDA are addressed in their operations and supplier arrangements.
- Procurement professionals sourcing cosmetics can use the guidance to assess whether supplier terms clearly allocate recall coordination and cost responsibilities.

**Jurisdictions:** federal
**Industries:** Healthcare
**Topics:** Regulatory Compliance
**Published:** November 04, 2026

### Government Entities
- U.S. Food and Drug Administration (FDA)

### Sources
- [Recall the Draft? FDA’s Final Guidance on Mandatory Cosmetic Recalls Looks Familiar | ArentFox Schiff - JDSupra](https://www.jdsupra.com/legalnews/recall-the-draft-fda-s-final-guidance-2825230) - JD Supra