The U.S. beauty industry returned to Capitol Hill last month with a clear message: regulatory deadlines are looming, global competition is intensifying, and American cosmetics companies need consistency, not confusion.
Industry leaders gathered on September 10 for the Personal Care Products Council's "Back-to-Session" reception, reconnecting with lawmakers as Congress returned from recess. More than a dozen companies came together to spotlight four critical issues shaping the sector's future: MoCRA implementation, non-animal testing expansion, tariff relief, and the need for regulatory consistency across state lines.
This wasn't ceremonial networking. With key rulemakings expected in late 2025 and early 2026, the stakes are tangible. Companies face compliance deadlines. States keep introducing conflicting ingredient bans. Trade tensions threaten supply chains. And breakthrough testing methods that could end animal testing need federal support to become standard practice.
"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," stated Karin Ross, the executive vice president of government affairs at PCPC. 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 almost three decades."
That economic weight gives the sector's regulatory requests credibility. But the message extends beyond protecting profits—it's about creating frameworks that work for businesses of all sizes while advancing science-based safety standards.
The MoCRA implementation hits a critical phase.
With the Modernization of Cosmetics Regulation Act establishing the first comprehensive federal oversight of cosmetics in over 80 years, PCPC members are closely watching how the FDA will roll out the remaining requirements.
Many companies have already completed initial requirements like facility registration and product listing. "We've worked to provide our members with the tools and resources necessary to navigate compliance," Ross said. But clarity on timing, scope, and enforcement remains a top concern.
The upcoming fragrance allergen and Good Manufacturing Practices rules carry particular weight. "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 explained.
Translation: small businesses need workable timelines and scalable requirements. Large corporations need consistency across facilities. Everyone needs to know what's expected and when.
Ross emphasized that PCPC is "monitoring to ensure the regulatory framework remains clear and workable." The diplomatic language conceals a serious industry concern about potential overreach or impractical requirements, which may seem reasonable on paper but can lead to operational challenges.
The challenge? MoCRA was meant to be a unified, science-based framework. But state-level ingredient bans and labeling rules are creating a patchwork of conflicting policies that undermine federal law.
"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."
For manufacturers with national distribution, such an arrangement creates impossible situations. Federally approved products may face bans in California, restrictions in New York, and different labeling requirements in Illinois. The compliance costs multiply. Innovation slows. Smaller companies without dedicated regulatory teams struggle to keep up.
non-animal testing gains momentum
Perhaps no issue generates more bipartisan support than ending animal testing for cosmetics. Non-animal testing continues as a high priority, with growing Capitol Hill backing for legislation that would formalize alternative methods 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 think about how to use non-animal testing methods more, the standards for evidence should be based on science, aligned internationally when possible, and adaptable as new methods are proven effective."
The industry isn't just talking about change—it's funding it. Companies have invested heavily in developing and validating non-animal testing methods that can assess safety more accurately and cost-effectively than traditional animal tests.
Two immediate legislative opportunities could accelerate progress: the Humane Cosmetics Act and provisions in the OMUFA reauthorization.
As Congress looks ahead to the next round of over-the-counter drug fees, 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 explained. "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."
If passed, the Humane Cosmetics Act would align U.S. regulations with other countries that have adopted animal test bans or regulatory frameworks emphasizing non-animal testing methods. The momentum is building—industry, advocates, and lawmakers increasingly agree that 21st-century safety science shouldn't rely on mid-20th-century testing protocols.
tariff relief targets essential inputs.
Supply chain pressures remain a persistent concern, particularly regarding tariffs on specialized ingredients and packaging not readily available domestically. 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.
The issue isn't about seeking shortcuts—it's about recognizing reality. The United States simply cannot manufacture certain specialized ingredients, advanced packaging materials, and processing equipment at scale. Tariffs on these essential inputs don't protect American jobs; they make American manufacturers less competitive globally while raising consumer prices.
PCPC is also pushing for recognition of the U.S.-Mexico-Canada Agreement 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."
The numbers back up this focus. 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.
That integrated North American market supports American jobs while providing regulatory consistency. Tariffs that disrupt those supply chains hurt everyone.
OTC reform remains on the agenda
While not the primary focus of the September event, over-the-counter drug reform remains important to many PCPC members, particularly regarding sunscreen active ingredients and approval processes.
The current system creates years-long delays for new ingredients already approved and widely used in other developed markets. Meanwhile, American consumers lack access to more effective, elegant sunscreen formulations available elsewhere.
Industry leaders want streamlined pathways that maintain safety standards while eliminating bureaucratic bottlenecks. The OMUFA reauthorization provisions addressing sunscreen review represent movement in that direction—if Congress preserves them through negotiations.
What's really at stake?
Strip away the policy jargon and lobbying language, and the industry's requests come down to practical concerns:
Can companies get clear guidance with enough lead time to comply without disrupting operations?
Could states consider harmonizing their regulations to avoid making national products unfeasible?
Can American manufacturers access essential inputs without punitive tariffs?
Will the U.S. embrace modern safety science that other countries already accept?
These aren't abstract regulatory debates. They affect whether companies can plan investments, hire workers, and compete globally. They determine whether breakthrough innovations quickly reach American consumers or languish in approval limbo for years. They shape whether the regulatory environment encourages or stifles the kind of science-based progress the industry champions.
The beauty industry's economic footprint—4.6 million jobs, $308.7 billion in GDP, and $82.3 billion in tax revenue—gives it significant influence. But influence only matters if translated into concrete policy outcomes.
As regulatory deadlines approach and international competition intensifies, the industry is betting that clarity, consistency, and science-driven reforms will prevail over patchwork restrictions and outdated protocols.
Whether Congress delivers remains to be seen. But the message from industry leaders is unambiguous: the current trajectory isn't sustainable, and the time for clarity is now.
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