
The U.S. Food and Drug Administration issued a Cosmetics Constituent Update on September 9, 2026, informing cosmetic product facilities, retailers, and responsible persons that the agency does not issue certificates or other documents to verify compliance with cosmetic product facility registration or product listing requirements. The clarification comes as FDA reports a rising number of inquiries from individuals seeking proof-of-compliance paperwork, driven in part by ecommerce platforms asking sellers to produce it before they can list products.
The Registration and Listing Framework
Under Section 607 of the FD&C Act, as amended by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), owners or operators of facilities that manufacture or process cosmetic products must generally register those facilities with FDA and renew the registration every two years. The responsible person for each marketed cosmetic product must also list the product with FDA, including its ingredients, and provide annual updates.
FDA was explicit on one point: registration and listing are neither a cosmetic approval program nor a promotional tool. Assignment of a facility registration number or a product listing number does not mean FDA has approved the facility or the products manufactured there. Those numbers confirm that a submission was made, not that FDA has evaluated or endorsed anything about the product.
Why FDA Is Addressing This Now
FDA noted that ecommerce platforms, including TikTok Shop, have been asking prospective sellers to provide proof of FDA registration, or, if a seller believes they are exempt, a letter or email from FDA confirming that exemption. Facilities and responsible persons have in turn been contacting FDA looking for a document the agency does not produce. FDA used the update to state plainly that no such certificate, verification letter, or exemption confirmation exists in any form, whether requested for a facility registration, a product listing, or an exemption claim.
What FDA Will Not Issue
FDA specified that it does not provide any of the following, regardless of who requests it or why:
- A certificate as proof of cosmetic product facility registration or product listing
- A verification document, such as a letter or email, stating that a facility is registered or a product is listed
- A document confirming that a facility or responsible person is exempt from registration or listing
What This Means for Importers and Responsible Persons
If a marketplace, retailer, or business partner asks you to prove cosmetic compliance, plan to work around the absence of a formal certificate:
- Point to your facility registration number or product listing number directly rather than looking for a separate confirmation document
- Keep your own submission confirmations and CDER Direct records as your internal proof of registration or listing status
- If claiming an exemption, be prepared to explain the basis for it yourself; FDA will not issue a letter confirming exempt status
- Treat any third party offering to obtain an FDA compliance certificate on your behalf as a red flag, since FDA does not issue one to anyone
Navigating cosmetic facility registration, product listing, or a marketplace compliance request?ASK Alba™: reach out to our trade compliance team at albawheelsup.com/contact-us
References
FDA Cosmetics Constituent Update, September 9, 2026
Registration & Listing of Cosmetic Product Facilities and Products
Guidance for Industry: Registration and Listing of Cosmetic Product Facilities and Products