How to Change Your MoCRA U.S. Agent: A Transfer Guide for Foreign Brands

By Vincent Cruz

Foreign cosmetic facilities sometimes need to switch their designated U.S. agent – because of pricing, responsiveness, or a provider that stopped answering emails. The good news: transferring is a routine amended filing, not a re-registration. Here is exactly how it works.

When switching makes sense

• Your agent is unresponsive when FDA correspondence arrives.
• You are paying enterprise rates for a designation-only service.
• Your provider shut down or stopped serving foreign cosmetics facilities.
• You want a clean, documented resignation process if you ever cancel.

The transfer process, step by step

1. Choose your new agent and sign authorization. The new agent will need a signed authorization to act on your facility’s behalf.

2. Gather your details. Your FEI number, current facility registration information, and facility contact details.

3. The new agent prepares an amended facility registration naming them as your U.S. agent.

4. Review and approve in writing. Check every field before anything is filed – the same discipline as an initial registration.

5. File the amendment. Once FDA processes it, the new agent is your facility’s official contact.

6. Notify your old agent in writing that their representation has ended, and ask them to forward any correspondence received during the transition.

What stays the same

• Your FEI number – it is tied to the physical facility, not the agent.
• Your registration history and product listings.
• Your renewal schedule — the amendment updates the agent on your existing registration, so your biennial cycle should be unaffected (confirm against your Cosmetics Direct record).

You do not need your old agent’s permission to switch. The change is made by filing the amended registration; the old agent does not approve or release anything in FDA’s system.

Mistakes to avoid

• A gap with no agent on record. Line up the new agent before ending the old arrangement – a foreign facility must have a designated agent at all times.
• Skipping the written notice. Tell the prior agent in writing, and get confirmation they will forward correspondence during the handoff.
• Assuming product listings transfer automatically. Listings belong to the responsible person and are separate from the facility’s agent designation – confirm both are current.

Switching to US MoCRA Agent

$450 one-time onboarding per facility, plus $34.99/month for continuous representation. We prepare the amended registration naming us as your agent, review every field with you, and file only after your written approval. Biennial renewal filing is included while you are subscribed – and if you ever cancel, we file a formal resignation instead of silently dropping your registration.

Start at usmocraagent.com or write to usmocra@outlook.com.

Frequently asked questions

How long does a transfer take?
Timing depends on how fast your documents come together — the amendment itself is quick to prepare and file once everything is in hand.

Will FDA notify my old agent?
Do not rely on that. Notify the prior agent yourself, in writing.

Does switching affect shipments in transit?
The agent designation is about FDA communication, not customs clearance per se – but an unresponsive or missing agent during an FDA inquiry can stall a shipment. Time the switch for a quiet period if you can.

Can I switch if my current agent is unresponsive?
Yes. Their cooperation is not required for the amended filing. Send the written notice anyway so there is a record.

US MoCRA Agent is a private service provider and is not affiliated with or endorsed by the FDA. This article is for informational purposes only and is not legal advice.