MoCRA Biennial Renewal: Keeping Your Facility Registration Current

Registering your cosmetic facility with FDA is not a one-time event. Under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), every facility registration must be renewed every two years — miss it, and your registration is no longer current.

This guide explains what biennial renewal is, how to find your due date, how to file through Cosmetics Direct, what happens if you miss your renewal, and how your U.S. agent keeps the whole process on track.

What biennial renewal is

MoCRA requires every person who registers a cosmetic product facility to renew that registration biennially — that is, every two years (section 607(a)(2) of the Federal Food, Drug, and Cosmetic Act). Renewal is how you confirm to FDA that your facility’s registration information is still accurate and that the facility remains active.

FDA offers two renewal paths in Cosmetics Direct, depending on whether anything changed:

• Biennial Renewal — for renewals with changes to your registration information.
• Abbreviated Renewal — for renewals without changes, when nothing has been updated since your most recent submission.

The abbreviated option exists because FDA recognizes that many facilities have nothing new to report at renewal time. But “nothing changed” still requires a filing — the renewal itself is mandatory either way.

When your renewal is due

Your renewal date is based on your initial registration date. FDA’s rule of thumb: renew every two years from the date FDA received your original registration. For example, if FDA received your initial registration on February 20, 2024, your renewal would be due by February 20, 2026.

A note on timing: you may see older references to renewing between October 1 and December 31 of even-numbered years. That was the schedule in MoCRA’s original statutory text, but FDA’s current guidance ties your renewal date to your own initial registration date instead. Follow the date FDA shows for your facility.

Finding your date is straightforward. Cosmetics Direct now displays each facility’s registration status and renewal date, and FDA sends automated renewal reminders to registered facilities. You can also renew early — FDA explicitly allows renewals before the two-year mark, for example to align with other FDA registration renewals your company already handles.

How to renew

Renewal is filed electronically through Cosmetics Direct, FDA’s portal for cosmetic facility registration and product listing. The process:

1. Log in to Cosmetics Direct and locate your facility registration.
2. Select the latest version of the Structured Product Labeling (SPL) for your submission.
3. Choose your renewal type — Biennial Renewal if any registration information changed, or Abbreviated Renewal if nothing changed.
4. Review and submit. Confirm every field is accurate before submitting; the renewal becomes part of your official FDA record.

Paper submissions are also accepted — FDA provides paper forms (including Form FDA 5066 for facility registration) — but the agency strongly encourages electronic filing through Cosmetics Direct for speed and accuracy.

Between renewals, keep your registration information current. If details like your facility address, contact information, or U.S. agent change, update the registration promptly rather than waiting for the next renewal cycle.

What happens if you miss your renewal

FDA has not published a specific grace period or late-renewal penalty for cosmetic facility registrations. But the biennial renewal is a statutory requirement, not a suggestion — a registration that isn’t renewed is no longer current, and operating with a lapsed registration is a compliance gap.

The practical consequences arrive before any enforcement action does:

• Your registration status goes stale. Cosmetics Direct displays registration status; partners, importers, and retailers who check it will see a facility that isn’t current.
• Business friction. U.S. importers and distributors increasingly verify facility registration. A lapsed registration raises questions at exactly the wrong moment — during a shipment or a contract review.
• Missed FDA communications. If your contact information changed and you never filed, FDA’s correspondence — including the renewal reminders themselves — may not reach you.

The fix is simple: don’t wait for the deadline. Renewal can be filed early, and the abbreviated renewal takes little effort when nothing changed. Put the date on a calendar with an advance reminder — or make sure someone is responsible for watching it.

How your U.S. agent helps

For foreign facilities, the U.S. agent is FDA’s official point of contact — which makes the agent central to renewal:

• Reminders reach the agent. FDA’s automated renewal reminders go to the contact on file for the facility. For a foreign facility, that email address is the U.S. agent’s — so a responsive agent means the reminder actually gets seen and acted on.
• Someone owns the deadline. Your agent tracks your renewal date and starts the process in advance, so renewal doesn’t depend on anyone remembering a date two years out.
• Accurate filings. The agent prepares the renewal submission, confirms whether the full or abbreviated path applies, and verifies acceptance — then keeps the submission record for your files.
• Continuity. If your agent changes between renewals, the incoming agent needs your FEI number and current registration details to file accurately. This is one more reason to manage agent transitions deliberately, never leaving a gap.

Make renewal someone’s job. The facilities that miss renewals aren’t careless — they just never assigned the task. Whether it’s your U.S. agent or an internal regulatory contact, one named person should own the renewal date.

New to MoCRA? Start with our complete MoCRA Compliance Guide for Cosmetic Brands (2026).

Frequently asked questions

How do I find my facility’s renewal date?

Log in to Cosmetics Direct — FDA’s 2026 portal update added a display of each facility’s registration status and renewal date. Your date is two years from FDA’s receipt of your initial registration.

Can I renew before my due date?

Yes. FDA allows renewals earlier than the two-year mark. Some companies file early to align the cosmetic renewal with other FDA registration renewals they already manage.

Nothing changed since we registered. Do we still have to file?

Yes — renewal is mandatory every two years regardless. But when nothing changed, you can use the abbreviated renewal, which is designed for exactly that situation.

Who receives FDA’s renewal reminders?

FDA sends automated renewal reminders to registered facilities through Cosmetics Direct. For foreign facilities, the contact email on file belongs to the U.S. agent, so keeping your agent’s information current is what keeps the reminders flowing to the right inbox.

US MoCRA Agent is a private service provider and is not affiliated with the FDA. Questions about biennial renewal: usmocra@outlook.com · +1 909-997-0000 · pricing.

This article is for educational purposes only and is not legal advice. US MoCRA Agent is a private service provider and is not affiliated with or endorsed by the FDA. Regulatory details are based on FDA’s published guidance and are current as of September 2026; always verify requirements against FDA’s official sources before acting.

Related Guides

• Cosmetics Direct: How to Register Your Facility Step by Step — file the renewal in FDA’s portal.
• How to Change or Transfer Your MoCRA U.S. Agent — update the agent before your renewal comes due.
• What Happens If You Don’t Register? MoCRA Non-Compliance Risks — operating on a lapsed registration.