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FDA MoCRA: Cosmetic Compliance & Registration

Before the Modernization of Cosmetics Regulation Act (MoCRA) was signed into law in December 2022, cosmetic manufacturers could legally sell products in the US without ever registering with the FDA or listing a single product ingredient. The FDA had no authority to recall unsafe cosmetics, no mandatory adverse event reporting system for cosmetics, and no requirement that manufacturers substantiate product safety. MoCRA changed all of that in a single legislative package — the most significant overhaul of US cosmetic regulation since the Federal Food, Drug, and Cosmetic Act of 1938.

MoCRA imposes mandatory facility registration, product listing, safety substantiation, adverse event reporting, and — for the first time — gives the FDA mandatory recall authority over cosmetics. On the Sustalium platform, the MoCRA-related compliance activity we see most is cosmetic brands and contract manufacturers reconciling their ingredient lists with the FDA's product listing format — because the FDA's electronic submission portal requires structured ingredient data, and most brands' internal records are not yet structured to match.

Electronics in the US: What Most Sellers Overlook

Starting an electronics brand costs more than most founders expect — and not because of manufacturing. It is the testing and certification. Every electronic product sold in the US requires FCC compliance as a matter of federal law. UL certification is commercially mandatory even where it is not legally required. And if you sell on Amazon, you need both plus a General Certificate of Conformity before your listing goes live.

This guide walks through launching an electronics product with the compliance planned and budgeted from the start.

On the Sustalium platform, the gap we see between electronics brands that launch on time and electronics brands that delay their launch by months is pre-compliance testing. The brands that send a prototype to the lab for a pre-scan before the formal FCC test identify emissions problems while they can still fix them at the PCB stage. The brands that go straight to formal testing discover the problem when the test report says "fail" — and they have already cut tooling.

Not sure which regulations apply to your electronics product? Use the Sustalium Global Compliance Map — select Electronics and your target market, and see every framework from FCC and UL to e-waste and Prop 65.

CA TPPA: Toxics in Packaging Compliance Guide

The Toxics in Packaging Clearinghouse (TPCH) — a coalition of 19 US states — regularly screens packaging for restricted heavy metals and publishes its findings. In its most recent screening report, the TPCH found that packaging from several major brands and retailers contained cadmium and lead above the 100 ppm threshold, with the highest concentrations appearing in inks, pigments, and plastic colorants rather than the base packaging material itself. This matters because the enforcement target is shifting: it is no longer enough to certify the substrate. Every component layer — inks, coatings, adhesives — must independently comply.

The California Toxics in Packaging Prevention Act (TPPA) — codified at Health and Safety Code §§ 25214.11–25214.26 — prohibits the intentional use of cadmium, lead, mercury, and hexavalent chromium in any packaging or packaging component sold or distributed in California. Nineteen other states have adopted identical legislation through the TPCH model. On the Sustalium platform, we see TPPA compliance appearing most frequently in packaging declarations for consumer goods, cosmetics, and food products — sectors where California distribution is essentially guaranteed and the multi-state nature of the requirement means companies must comply across a patchwork of state laws with a single, consistent Certificate of Compliance.

Importing Toys Into the US: What Nobody Tells You

Toys are the most regulated consumer product category in the United States — and the compliance cost is not optional. Unlike adult furniture or general apparel, where you can issue a GCC based on a reasonable testing program, every toy sold in the US requires third-party testing at a CPSC-accepted laboratory, a Children's Product Certificate (CPC), and a tracking label permanently affixed to the product.

If you are importing toys for the first time — whether you designed them yourself or are sourcing from a manufacturer — the compliance path is the same. On the Sustalium platform, the single most common CPC rejection we see is a mismatch between the manufacturer name on the certificate and the importer name on the seller account. The testing is fine. The paperwork is wrong. Here is what you need before your toys reach a US port.

Not sure which CPSC standards apply to your toy? Use the Sustalium Global Compliance Map — select Toys and the US, and see every applicable framework from ASTM F963 to state packaging rules.

US Clothing Brand: The Rules Most Founders Miss

Starting a clothing brand looks simple: design some pieces, find a manufacturer, launch a website. What catches most first-time apparel founders off guard is the compliance — not the design. Your fabric choice affects which flammability standard applies. Your trim supplier determines whether you need a Prop 65 warning. Your packaging can make your product illegal in California if it fails a heavy metal test.

This guide walks through launching a clothing brand with the compliance steps built in at each stage — so you are not reworking labels and repackaging inventory the week before launch.

On the Sustalium platform, the apparel compliance issue we see most often is not missing flammability tests — it is missing Prop 65 assessments. A brand launches a clothing line with a valid GCC, correct FTC labels, and compliant packaging. Six months later, a Prop 65 enforcement notice arrives because a metal zipper or a screen-printed design contained a listed chemical above the safe harbor level. The testing costs $300. The settlement costs 100 times that.

Not sure which rules apply to your clothing brand? Use the Sustalium Global Compliance Map — pick your market and product type, and see every framework from CPSC flammability to state PFAS restrictions.

US Lacey Act: Import Declaration for Plant Products

In 2023 and 2024, US Customs and Border Protection stepped up seizures of imported wood products with incomplete or inaccurate Lacey Act declarations — including multiple container-loads of hardwood flooring and furniture from Southeast Asia. CBP's enforcement focus has shifted from high-profile criminal prosecutions to routine port-level verification: if the species, country of harvest, or quantity on your PPQ 505 form does not match the shipment, the goods are detained, and the importer of record bears the cost of storage, re-export, or destruction.

The US Lacey Act (16 U.S.C. §§ 3371–3378) was originally enacted in 1900 to combat wildlife trafficking. The 2008 amendment extended it to plants and plant products, creating a mandatory import declaration regime that covers an enormous range of goods — from raw timber to finished furniture, paper, and musical instruments. On the Sustalium platform, we see Lacey Act declarations becoming a more frequent request in the furniture and construction materials supply chains, as US retailers strengthen their import compliance programs.

FDA Food Contact Material: Compliance Guide

In 2023, the FDA issued warning letters to multiple manufacturers of food contact articles — including a major manufacturer of reusable plastic food containers — for failing to provide adequate documentation that their food contact substances were approved for their intended use. The common thread in all the letters: the companies had test data showing their products were safe, but they could not produce a properly structured Declaration of Compliance that mapped each substance in the material to its regulatory clearance. The FDA's position was unambiguous: data without a properly structured declaration is not compliance documentation.

Under the Federal Food, Drug, and Cosmetic Act (FFDCA) and 21 CFR Parts 170–199, any material intended to contact food during manufacturing, packaging, storage, or preparation must be approved by the FDA or be Generally Recognized as Safe (GRAS). The manufacturer or supplier issues a Declaration of Compliance (DoC) — a self-declared document that certifies the material meets FDA regulatory requirements. On the Sustalium platform, food-contact declarations are one of the most cross-referenced document types we see: a food packaging supplier issues a Declaration of Compliance to its downstream customer, who must then present it to their own buyer or retailer audit.

Selling Food Online in the US: The Rules You Need

You have a recipe people love. You want to turn it into a product. Maybe it is candy, hot sauce, granola, or frozen meals. The part most first-time food entrepreneurs underestimate is not the recipe — it is everything that happens after the recipe is finalized. Commercial production, food safety regulation, packaging compliance, labeling, shelf-life testing, and distribution.

This guide walks through the end-to-end process of launching a food product in the United States, with the compliance obligations woven in at the stage where they actually apply — not as a separate document you deal with later.

On the Sustalium platform, the compliance document most first-time food entrepreneurs are missing is not the FDA registration or the food safety plan — it is the Declaration of Compliance for their packaging. They have the food safety documentation. They do not have the food contact material compliance. And when a retailer or Amazon asks for it, the gap stops the launch.

Not sure which regulations apply to your food product? Use the Sustalium Global Compliance Map — select your product category and target country, and see every regulatory framework that applies, from FDA food safety to state-level packaging rules.

SMETA Audit Guide: Sedex Social Compliance

Sedex reports over 75,000 members across 180 countries, with more than 340,000 SMETA audits conducted globally. The most common non-compliance findings — working hours, wages below the legal minimum, and inadequate health and safety controls — appear consistently across the textile, electronics, and agriculture sectors. Under the UK Modern Slavery Act, brands like Marks & Spencer, Tesco, Unilever, and Primark explicitly cite SMETA audit programs in their public modern slavery statements, and the EU's CSDDD now extends similar due diligence obligations across the entire bloc. For a supplier, a lapsed or missing SMETA report increasingly means automated deselection from buyer procurement systems — often before a human reviewer ever sees the application.

SMETA (Sedex Members Ethical Trade Audit) is the most widely used social compliance audit methodology in the world. It assesses working conditions across labor standards, health and safety, environmental management, and business ethics. For suppliers in apparel, textiles, electronics, furniture, and FMCG, a current SMETA audit report is often the price of admission to the Western buyer market. On the Sustalium platform, we see the same buyer who requests a CE Declaration of Conformity now routinely asking for the most recent social audit — because procurement teams are being measured on supply chain risk, not just product compliance.

US vs. EU Food Contact: One Product, Two Frameworks

A food packaging product sold in both the United States and the European Union must satisfy two separate food contact regulatory regimes — and neither accepts the other's documentation. The FDA Declaration of Compliance cites 21 CFR regulations and Food Contact Notifications. The EU Declaration of Compliance cites Regulation (EC) 1935/2004 and material-specific measures like the Plastics Regulation (EU) 10/2011. The migration testing is similar but the test conditions, simulants, and limits differ. And a Declaration of Compliance valid in one market is not valid in the other.

This guide compares the two systems, identifies the key operational differences, and explains how to build dual-market food contact compliance without duplicating every test.