In this episode, I sit down with FDA compliance attorney Heather Butos to unpack two topics most cosmetic pros ignore until it’s too late: INCI (ingredient) names and MOCRA (the new cosmetic law).

We talk about how ingredient naming is not just labeling, it’s a strategic business decision that can make or break product marketing. Heather breaks down how the Personal Care Products Council influences naming conventions, why companies struggle to sell ingredients when they can’t describe them well, and what’s actually allowed under FDA rules.

We also dive into the Modernization of Cosmetics Regulation Act (MOCRA). We discuss what’s already in effect, what’s still vague, and why this transition period is both confusing and critical. Along the way we share real-world GMP audit stories, how COVID shaped compliance, and why walking the factory floor gives better regulatory insight than just reading guidance documents.

This is not your typical cosmetic compliance talk. If you make or sell cosmetics, personal care products, or ingredients, pay attention.

Show Notes (Bulleted)

• What are INCI names and why they exist
• The Personal Care Products Council and how INCI naming works
• How ingredient naming crosses into marketing strategy
• Real-world examples of label creativity and regulatory risk
• Making sense of MOCRA — what’s live, what’s stuck
• Why registration, adverse event reporting, and safety substantiation matter now
• What we still don’t know about cosmetic GMP enforcement
• GMP audits vs desk compliance — why experience matters
• U.S. vs EU regulatory contrast (quick take)
• Tips for staying compliant while FDA rules evolve

What You’ll Learn

• How to think about ingredient names as part of your product strategy
• What’s actually required vs what’s still vague in cosmetic regulation
• How the naming process works with industry groups
• How MOCRA changes the compliance landscape
• Real compliance lessons from factory audits

Resources Mentioned

• Personal Care Products Council
• MOCRA (Modernization of Cosmetics Regulation Act)
• Cosmetic registration and listing
• Adverse event reporting basics

Who This Is For

• Cosmetic brand owners and founders
• Ingredient suppliers and formulators
• Regulatory affairs professionals
• Legal and compliance teams
• Anyone confused by cosmetic labeling rules

Recommended Chapters (Timestamped)

Use these in Buzzsprout chapter markers:

0:00 — Intro
1:30 — What INCI ingredient names are
3:30 — How ingredient naming affects marketing
7:00 — Creative labeling and regulatory limits
10:00 — GMP audits and manufacturing reality
13:50 — What MOCRA is
16:30 — Which MOCRA rules are live
19:00 — What’s still vague or coming
21:30 — EU vs US differences
24:00 — Tips for compliance
27:00 — Outro

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