Beauty & Cosmetics ยท For mid-market and enterprise importers
Get beauty products through U.S. customs in time for the launch.
A launch date with a retailer does not move because a shipment is waiting on FDA. We make sure the MoCRA, labelling and customs information is in place before your products ship, and use the same record to pay the lowest duty the law allows.
Why beauty products get stuck at the border.
Cosmetics are reviewed by two agencies at the border: CBP for duty, origin and value, and FDA for whether the product may enter at all. Since the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), FDA expects far more from importers than it used to, and most holds come from information that was missing or did not match.
- Registration and listing gaps. Under MoCRA, facilities that make cosmetics for the U.S. must be registered with FDA and each product listed by its responsible person. Foreign facilities also need a U.S. agent.
- A cosmetic that is really a drug. Sunscreens, SPF moisturisers, acne and anti-dandruff products are regulated as over-the-counter drugs, with separate registration, listing and labelling rules. Filing them as cosmetics is a common cause of refusal.
- Colour additives and ingredients. Colour additives must be approved for their intended use, and some require FDA batch certification. An unapproved colourant can stop an entire shipment.
- Labels. Ingredient declaration, net quantity, U.S. contact details for adverse-event reports, and a country-of-origin marking on each container.
All of these are paperwork questions. They can be checked, and fixed, before the goods leave the factory.
What we do for beauty brands.
| When | What we do | What it is worth |
|---|---|---|
| Before the purchase order | Landed cost by product and supplier: duty, fees and delivered cost, including sets, kits and gift-with-purchase packs. | You know the margin on the U.S. range before you commit to the order or the retail price. |
| Before the goods ship | MoCRA registration and listing, FDA entry data, ingredient and label information and the commercial documents checked against each other. Gaps go back to the manufacturer while the goods are still in the warehouse. | Product reaches the retailer in time for the launch, and your team is not chasing a lab for a document in launch week. |
| Every product, every launch | One record per product: ingredients, origin, classification and value. Reused on every reorder and every new shade or size. | The broker supports the correct duty treatment instead of the default one, and FDA and CBP questions are answered from the file. |
Every duty position is reviewed and signed by a licensed U.S. customs broker: our broker partner, or your existing broker working from the same record.
What it changes, on one real programme.
We helped a medium-sized European skincare company model its landed cost, find $305,000 in annual duty savings, and enter the U.S. market on better terms. Greenwich built the product record; the licensed broker used it to support a lower rate on a group of its products and put their name on the entry.
Figure is modelled across that company’s planned annual imports and the client is anonymised at their request. It is a duty reduction identified and supported on their products, not a rate we can promise on yours.
Beauty is full of products that sit close to the line between two tariff headings: a serum or a lotion, a set or its contents, a make-up product or a skin-care product. The rate follows the heading, so the evidence behind it is worth money.
How the first piece of work is scoped.
One product range or one manufacturer. A defined output, a fixed fee and a delivery date. You keep the output whether or not anything follows it.
Before that, 20 minutes to find out whether there is a problem worth pricing: which products cause questions at entry, where MoCRA or label information is incomplete, and what a late shipment costs you against a retail launch.
Questions, answered directly.
How do you import cosmetics into the U.S.?
Classify each product correctly, make sure it is a cosmetic and not an over-the-counter drug, confirm the manufacturing facility is registered with FDA and the product listed under MoCRA, check that ingredients and colour additives are permitted and the label meets FDA rules, and file the entry through a licensed customs broker with the FDA data CBP transmits to FDA. Most delays come from one of these steps being incomplete when the goods arrive.
What is MoCRA and what does it require of importers?
The Modernization of Cosmetics Regulation Act of 2022 is the biggest change to U.S. cosmetics law since 1938. It requires facilities that manufacture or process cosmetics for the U.S. to register with FDA, requires the responsible person to list each product, report serious adverse events and keep records substantiating product safety, and requires U.S. contact details on labels for adverse-event reports. Foreign facilities must name a U.S. agent.
Do cosmetics need FDA approval before import?
Most cosmetics do not need FDA approval before they are sold, but colour additives must be approved for their intended use, and products that make drug claims, such as SPF protection or treating acne, are regulated as drugs with their own requirements. FDA can refuse admission to cosmetics at the border if they appear adulterated or misbranded.
Can Greenwich lower the duty we pay on beauty products?
Often, by making sure each product is classified and valued correctly and the record supports it. We helped one medium-sized European skincare company find $305,000 in annual duty savings. Any saving depends on your actual products and documents, and every duty position is reviewed by a licensed U.S. customs broker.
Can you guarantee our shipments will not be held?
No. FDA and CBP can examine or hold any shipment. What we prevent is the avoidable kind of hold: the one caused by missing or inconsistent registration, listing, label or commercial information. That is the most common kind, and the easiest to fix before products ship.
Is Greenwich a licensed customs broker?
No. Greenwich builds the landed-cost model, the pre-entry document pack and the product record. A licensed U.S. customs broker reviews the duty position and files the entry under their own power of attorney: our broker partner, or your existing broker working from the same record.
Sources and limits
- FDA: Modernization of Cosmetics Regulation Act of 2022
- FDA: cosmetic facility registration and product listing
- FDA: importing FDA-regulated products
- FDA: colour additives and cosmetics
Sources support the stated context. They are not an endorsement of Greenwich and not a determination on your shipments. Nothing on this page is a duty quotation.
Twenty minutes with whoever owns your U.S. imports.
Tell us which products, manufacturers and launches matter most. We will tell you honestly whether there is anything worth doing.
Or write to cameron@greenwich-mercantile.com.