What MoCRA actually requires
MoCRA gives the FDA real authority over cosmetics for the first time. Every facility that manufactures or processes cosmetic products for the US market must register and renew every two years. Every product must be listed, with the Responsible Person on the label declared to the FDA. Every brand must hold safety substantiation that supports each product. Serious adverse events must be reported within 15 business days. Mandatory recall authority sits on top of all of it.
In a spreadsheet stack, every one of these obligations is a separate file, a separate owner and a separate point of failure. The FDA does not care which spreadsheet is out of date. MoCRA was written assuming brands would build a real system of record. Most have not, and the audit risk compounds quietly.
