Cosmetics Direct Gets Two Portal “Fillers” – Discontinuation and Relisting Features Added
Client Alert | 1 min read | 08.06.24
On July 29, 2024, FDA announced that it added two new features to Cosmetics Direct, the electronic submission portal used for the facility registration and product listing requirements now in effect under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). The portal now allows responsible persons to “discontinue” and “relist” cosmetic products.
Here’s how it works: rather than deleting a cosmetic product that is no longer on the market, the responsible person (i.e., the manufacturer, packer or distributor whose name appears on the product’s label) can now select “discontinue.” The practical effect of selecting “discontinue” is that the product’s information will remain in the Structure Product Labeling file on Cosmetics Direct, rather than being permanently deleted. The corresponding “relisting” feature enables the responsible person to relist any discontinued cosmetics that are being put back on to the market. Together, these new features provide a more efficient experience for the responsible person, who would otherwise have to start over and list a new product if and when a discontinued cosmetic is being put back on the market—e.g., after a temporary decision to stop sales.
To view more details about these new features, as well as instructions on how to use the Cosmetics Direct portal, FDA published an updated User’s Guide.
These changes come approximately one month after FDA began enforcing MoCRA’s product listing and facility registration requirements on July 1, 2024, and show FDA is taking steps to make compliance with MoCRA more user friendly. Responsible persons should review and monitor FDA’s Cosmetics Direct webpage to keep abreast of the latest resources for registration and listing of cosmetic products. We will continue to monitor and report on the latest developments as well.
Contacts
Insights
Client Alert | 2 min read | 07.15.26
CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations
As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights.
Client Alert | 3 min read | 07.15.26
Client Alert | 3 min read | 07.14.26
Client Alert | 3 min read | 07.13.26
Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

