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MoCRA 2022
For our Personal Care product manufacturers, the effective date for the U.S. Modernization of Cosmetics Regulation Act (MoCRA) is December 29, 2023. There are no gluten-related regulations in this new act, but it does require the following from manufacturers who make products such as makeup, nail polishes, shaving cream, grooming products, perfumes, face and body cleansers, haircare products, moisturizers, and skincare products:
- Facility registration with biennial renewal
- Listing all cosmetic products and their ingredients with the FDA
- Adverse event reporting and record-keeping
There are also additional labeling requirements and requirements for the FDA to establish GMPs for the cosmetics industry, as well as a list of “fragrance allergens” and rules for declaring these on packaging. You can learn more about MoCRA on the FDA website.
The Cost of Gluten-Free Recalls
A recent article in the journal Nutrients looked at the impact of gluten-free product recalls on consumer trust. This study, done at the University of Guelph, solicited 1175 survey responses from supporters of Celiac Canada, 70% of whom indicated they had been personally affected by gluten contamination-related recalls.
When asked “What strategies do you feel would be more effective in restoring your consumer trust after a gluten-related recall of a gluten-free product?”, sixty-four percent of respondents chose the response “Disclosure on the source of the problem and possible mitigation strategies”. In response to this same question, 58% percent of respondents chose “Communication strategies (e.g., an apology)”, and 53% chose “Compensation (e.g., a monetary compensation or coupon)” This study seems to indicate that transparency and the steps taken to make sure the problem does not recur are the most important part of a recall response for consumers.
You can read the original publication, including additional interesting findings, here.
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