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FDA Publishes SPL Guide for MoCRA Facility Registration and Product Listings

Client Alert | 1 min read | 11.01.23

On October 13, 2023 he FDA announced that two of the requirements set forth in the Modernization of Cosmetics Regulation Act of 2022 (MoCRA)— facility registration and product listing—will be included as part of the Structured Product Labeling (SPL) framework. SPL is a document formatting standard adopted by FDA for exchanging product-related information. 

The FDA previously developed Cosmetics Direct, a draft electronic portal for submissions under MoCRA. Companies who will use Cosmetics Direct may submit facility registration information and/or product listings by importing an SPL document, which contains user friendly data entry forms, performs initial validation, creates and saves the SPL submission, and submits the SPL document to FDA for internal processing.

In order to assist those who will be using and uploading SPL documents, the FDA also published a SPL Implementation Guide with technical conformance criteria for SPL documents. According to this Guide, importing an existing SPL document will be useful for bulk submissions, and users will be able to copy a successfully uploaded SPL document as a starting point for their own submission.

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Client Alert | 3 min read | 04.26.24

CFIUS Proposes Enhanced Enforcement and Mitigation Rules and Steeper Penalties for Non-Compliance

On April 11, 2024, the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”) announced proposed amendments to its enforcement and mitigation regulations, marking the first substantive update to CFIUS’s mitigation and enforcement provisions since the enactment of the Foreign Investment Risk Review Modernization Act of 2018.  The Committee issued a notice of proposed rulemaking ("NPRM”) that would modify the regulations that apply to certain investments and acquisitions, as well as real estate transactions, by foreign persons as follows:...