Beauty and Cosmetics Logistics for US Importers

MoCRA is the Modernization of Cosmetics Regulation Act, signed into law in December 2022. It is the most significant update to FDA cosmetics oversight since the Federal Food, Drug, and Cosmetic Act of 1938. MoCRA requires cosmetic manufacturers and processors to register their facilities with FDA and list every cosmetic product manufactured or processed there. It also requires that importers be able to document that their foreign suppliers are complying with FDA safety and labeling requirements. Facility registration opened in late 2023 and is now a standing requirement. For importers, the practical impact is that shipments from facilities that are not registered with FDA, or from suppliers who cannot provide registration documentation, are at elevated risk of examination and hold at the port of entry. We verify facility registration status for each supplier before the first shipment and confirm it is current whenever a new product or manufacturing site is added to the program.

Aerosol cosmetics including hairsprays, dry shampoos, and spray deodorants are classified as dangerous goods under both IMDG (ocean) and IATA (air) regulations due to pressurized containers and propellant content. Nail polishes, nail polish removers, and nail treatments containing flammable solvents classify as flammable liquids. Perfumes and colognes with high alcohol content classify as flammable liquids above a minimum flash point threshold. These products require specific dangerous goods declarations, UN number identification, proper packaging specifications, and carrier pre-approval before loading. Quantity limits apply to DG cosmetics on air shipments and differ from ocean limits. We classify your product mix against DG regulations before booking and confirm carrier acceptance ahead of loading so there are no rejections at the port of origin.

Yes. The KORUS (US-Korea Free Trade Agreement) reduces or eliminates MFN duty on most cosmetic and personal care products originating in South Korea. Under KORUS, cosmetics in HTS headings 3303 through 3307 generally qualify for a zero or near-zero duty rate with proper certificate of origin documentation. South Korean cosmetics are also not subject to Section 301 tariffs, which apply only to Chinese-origin goods. For brands running both Chinese and South Korean sourcing, the duty differential between the two origins can be meaningful: a Chinese-origin foundation in HTS 3304 carries standard MFN duty plus 7.5 percent Section 301, while the same product manufactured in South Korea carries zero duty under KORUS. The tradeoff is typically unit cost and minimum order quantity from Korean contract manufacturers versus Chinese alternatives.

Cosmetics sold in the US must carry a label with the product identity, net quantity in US measurements, ingredient declaration using INCI names listed in descending order of predominance, and the name and address of the manufacturer, packer, or distributor. Warning statements are required for specific product categories including aerosols, products near the eyes, and products with specific ingredient risks. A label that is missing required elements, uses non-INCI ingredient names, or makes claims that FDA classifies as drug claims rather than cosmetic claims can trigger an examination hold at the port. Drug claims on a cosmetic label can cause the product to be regulated as an unapproved new drug, which is a more serious classification than a labeling violation. We review label artwork before production runs on new SKUs so compliance issues are caught at the supplier, not at CBP.

FDA classifies a product as a cosmetic if it is intended to cleanse, beautify, promote attractiveness, or alter appearance. It classifies a product as a drug if it is intended to affect the structure or function of the body or to treat or prevent disease. The distinction matters because cosmetics and drugs face different regulatory pathways: cosmetics require MoCRA compliance and proper labeling, while drugs require pre-market approval or an OTC monograph. Products that make both cosmetic and drug claims, such as sunscreens, anti-dandruff shampoos, and fluoride toothpastes, are regulated as both under FDA rules. For importers, the risk is that marketing language on packaging or in accompanying materials crosses the line from cosmetic claims into drug claims, triggering a more complex regulatory review at the port of entry. We flag label language that may create drug claim risk during pre-shipment review.

Mixed DG and non-DG shipments are common in beauty programs where a single container carries aerosol and non-aerosol formats from the same vendor. IMDG regulations allow DG and non-DG cargo in the same FCL container subject to segregation requirements based on the specific UN hazard class involved. Aerosols classified as Class 2.1 (flammable gas) or Class 2.2 (non-flammable gas) and flammable liquids classified as Class 3 have specific stowage and segregation rules that apply at the container packing stage. We coordinate DG cargo packing at origin to ensure the container load plan meets IMDG requirements, with documentation prepared for both the DG and non-DG portions of the shipment so the carrier accepts the container without amendment at the port of loading.

Yes. Sephora, Ulta, Target, and specialty beauty retail accounts each have routing guide requirements that apply on top of FDA and customs compliance. These include specific carton labeling formats, GS1-128 barcode requirements, EDI 856 ASN transmission windows, pallet configuration specs, and in some cases retailer-specific quality inspection requirements before DC delivery. We load routing guide specs for each active retail account into your program profile and apply them on every booking. For new retail account launches, we run a pre-shipment compliance review against the new routing guide before the first container ships so the DC delivery meets requirements on the first attempt rather than generating a chargeback on the initial order.

South Korea to the US West Coast from Busan or Incheon into Los Angeles or Long Beach runs 12 to 15 transit days, one of the shorter ocean lanes into the US from Asia. Door-to-DC planning window including origin booking, customs clearance, and drayage runs 20 to 28 days total. China to the US West Coast from Shanghai or Ningbo runs 14 to 18 transit days with a similar door-to-DC window of 22 to 32 days. European air freight from Paris or Milan into US East Coast airports runs 2 to 4 days door-to-door. For beauty programs with hard floor-set or launch dates, we build the booking schedule backwards from the retailer DC appointment, accounting for FDA examination risk on new suppliers and DG carrier acceptance timelines on aerosol-heavy shipments.