Attorneys On Modernized Cosmetic Regulations And New Litigation Risks
Greenberg Traurig and Hogan Lovells attorneys provide first breakdowns of the game-changing Modernization of Cosmetic Regulations Act, including the potential for new lawsuits and plaintiff tactics.
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Cosmetic product manufacturers can expect the plaintiffs’ bar to leverage new record-keeping, GMP and other provisions of the Modernization of Cosmetic Regulations Act to bring or advance litigation, Crowell & Moring attorneys say. They note some defensive tactics that could prove effective.
If the FDA reviews companies’ product information submitted under the Modernization of Cosmetics Regulations Act of 2022, which is due by 29 December 2023, and denies product listings deemed noncompliant, that could place products containing unapproved color additives and certain drug active ingredients, for example, in violation of the law.
FDA announces plans to make submission portal available in October for meeting registration deadlines for facilities and product listings under Modernization of Cosmetics Regulation Act. Guidance also provides more specifics on data that should be submitted to agency.