Cosmetics Sales on Amazon in the U.S.: MoCRA and FDA Compliance Guide (2026)

Cosmetics Sales on Amazon in the U.S.: MoCRA, FDA Compliance, and a Guide to Getting Started Right

Cosmetics sales on Amazon in the U.S. are among the top topics Turkish skincare and cosmetics manufacturers have been researching most in recent years. The reason is clear: The U.S. is the world’s largest beauty and personal care market, and e-commerce’s share of this market is growing every year. In skincare, the trends toward “clean beauty,” simple formulations, and natural ingredients align perfectly with the production quality and ingredient narratives—areas where Turkish manufacturers excel.

But let’s be honest: it’s not an easy marketplace. There are thousands of listings in key categories like vitamin C serums, hyaluronic acid, and retinol, along with substantial advertising budgets and established brands. For a manufacturer looking to sell cosmetics on Amazon, success depends on two things even before product quality: setting up the regulatory framework correctly and having the right entry strategy. The part that challenges most brands isn’t the listings themselves; it’s the regulatory and operational layer beneath them. Since late 2023, the cosmetics industry in the U.S. has been significantly overhauled by MoCRA (the Modernization of Cosmetics Regulation Act), and these rules directly apply to manufacturing facilities in Turkey as well.

In this article, drawing on the experience of a skincare manufacturer we advise, we provide a step-by-step guide to the strategy, MoCRA compliance, labeling, branding, and sales aspects of their journey on Amazon U.S.

Why Is the U.S. Cosmetics Market Attractive to Turkish Manufacturers?

With a size exceeding 100 billion dollars, the U.S. beauty and personal care market is the world’s largest single market; skincare is one of the fastest-growing segments of this market. Two trends stand out in consumer behavior: a group of consumers who shop by reading ingredient lists and are well-versed in INCI information, and a growing preference for “fewer but better ingredients.” The K-beauty wave has proven one thing: U.S. consumers are open to foreign brands that have a compelling story and deliver quality.

Turkey’s cosmetics manufacturing infrastructure offers a significant advantage for manufacturers looking to transition from contract manufacturing to their own brands. When combined with logistical proximity at the customs border and competitive production costs, cosmetics exports to the U.S. become a sustainable growth channel when properly structured. We have also discussed why Turkish manufacturers are turning to this process in this article.

Strategy First: Testing in Turkey, Transition to the U.S.

In our case study, the seller listed approximately 10 SKUs on Amazon Turkey before expanding to the U.S., using real PPC data and listing optimization to drive results. We believe this approach was the right choice: testing the product-content-price equation in the local market lays the foundation for the U.S./EU expansion. Entering the U.S. market with knowledge of which products convert, which images perform well, which price points turn clicks into sales, and the actual cost per click provides a very different starting point compared to entering based on guesswork.

The second strategic decision was choosing a niche. Mainstream categories (vitamin C, hyaluronic acid) require time and a relatively high budget to gain visibility; click costs are already high in the cosmetics industry. In contrast, starting with more niche, natural-ingredient products in the portfolio can help keep competition low and make it easier to gradually build brand awareness. On Amazon U.S., the choice of the first entry product is often more decisive than the formulation itself. The right question isn’t “Which is my best product?” but rather, “Which of my products has a competition-to-demand balance that works in my favor?”

Criteria We Consider When Selecting Entry-Level Products

• Search volume / competition balance: How many listings are competing for the main keyword, and what is the number of reviews for the brands on the first page?
• Differentiation narrative: Can the product’s content or concept be explained in a single sentence in the visual and the headline?
• Unit economics: FBA fees, shipping, and advertising—the margin after these costs; the advantage of small/light products in the cosmetics category creates a real cost difference.
• Regulatory burden: Products with a low likelihood of running into issues with claim wording and additional testing requirements are easier to bring to market initially.

What Is MoCRA? The New Set of Rules for Cosmetics in the U.S.

The short answer to the question “What is MoCRA? ” is: the most comprehensive update to U.S. cosmetics regulations since 1938. This law, which expands the FDA’s authority over cosmetics, imposes registration, notification, and safety obligations on all manufacturers—both domestic and foreign—that market products in the U.S. A manufacturer based in Turkey that sells to Amazon U.S. is also fully subject to these rules.

Facility Registration

The facility that manufactures the product (the factory in Turkey) must be registered with the FDA as a cosmetics facility. The registration is renewed every two years. In contract manufacturing, the registration obligation falls on the facility that actually carries out the production; the brand owner must clarify this with their supplier.

US Agent: U.S. Point of Contact

A U.S. agent must be appointed for foreign facilities. The U.S. agent serves as the point of contact between the facility and the FDA; the agent does not hold any rights to the product or brand. Having a service provider that is based in the U.S. and has legal entity status assume this role simplifies the process.

Product Listing

Every cosmetic product introduced to the market must be reported to the FDA system along with its ingredient information. New products are listed within a certain period after entering the market; updates are made in the event of formulation changes. As the number of SKUs increases, the regular management of these reports becomes an operational task in its own right.

Safety Substantiation

MoCRA requires that the safety of every product be verifiable. This does not mean new testing for every product; rather, it means a dossier supported by existing scientific data, ingredient safety assessments, and, where necessary, product testing. For manufacturers who have prepared a PIF (Product Information File) in the EU, this dossier serves as an important starting point.

Label and INCI Format

The label is expected to include the name of the responsible person, a list of ingredients, and the required warnings. The ingredient list must be prepared in INCI format; labels prepared with Turkish ingredient names or free translations are not valid in the U.S. Allergen disclosure for fragranced products is also on the agenda; the INCI breakdown of the formulation must be finalized before beginning label design. For practical steps regarding FDA requirements, please refer to our FDA Registration and Certification guide.

Does the FDA Approve Cosmetics? The Most Common Misconception

No. The FDA does not grant prior approval for cosmetic products; there is no such status as “FDA-approved cosmetics,” and using this phrase in marketing is misleading. The correct context is this: The FDA regulates cosmetics through registration and notification; it does not approve products. When your customers or Amazon ask for an “FDA certificate,” what they mean is facility registration, product listing registration, and compliance documentation. Understanding this distinction protects you from making false claims and ensures you communicate with the other party using the correct terminology.

Amazon Side: Listing, Brand, and Claim Management

Brand Registry and Brand Awareness

In the cosmetics industry, visual storytelling is the key to sales, and Amazon’s powerful content tools (A+ Content, Brand Store, video) are unlocked through Brand Registry. This requires a trademark that is either registered or pending in the U.S.; filing the application before shipping products ensures that all tools are ready on launch day. For more details, see our Amazon Brand Registry guide and our guide to trademark registration in the U.S.

Claim Language: Cosmetics or Medicines?

In the U.S., what classifies a product as a cosmetic or a drug is its claims as much as its formula. “Moisturizes, improves appearance” is a cosmetic claim; statements like “treats acne, heals eczema, stimulates cell regeneration” shift the product into the drug category and create issues with both the FDA and Amazon. Listing text, text on images, and A+ content—all must pass through this filter. Our experience shows that when the language of the claims is set up correctly from the start, there’s no stress later on regarding listing removals.

Amazon's Category and Testing Requests

Although the cosmetics category is generally open, Amazon may require additional documentation for certain product groups; for example, we’ve seen requests for laboratory test reports for products that claim to brighten the skin or reduce dark spots. If your product lineup includes such SKUs, incorporating testing and documentation into your launch plan from the outset will help prevent delays.

Search Terms and PPC

• Use real search language: U.S. consumers search for terms like “niacinamide serum,” “fragrance-free moisturizer,” and “vitamin C serum for the face”; thinking in Turkish and then translating limits visibility from the start.
• Discovery through automated campaigns: During the launch , use automated PPC to see which search terms Amazon matches your product to; then move the terms that drive conversions to a manual campaign (exact/phrase).
• Negative keyword strategy: Clicks are expensive in the cosmetics industry ; cutting spending on irrelevant searches from the very first weeks significantly lowers ACoS.
• Comments and social proof: Scenarios for the first comments that comply with the Vine program and insert card rules; social proof is the most powerful driver of conversion in the cosmetics industry.

Phase Two: The European Market

The question that arises simultaneously with the U.S. is Europe. The EU has a separate set of rules: a responsible person established in the EU, a CPNP notification for each product, an EORI number, VAT registration in the destination country, Germany’s packaging law (VerpackG/LUCID), and GPSR compliance. This layer is independent of the U.S. and constitutes a project in its own right. Our experience suggests that it’s more effective to establish a solid foundation in one market—starting with the U.S.—before moving on to the other, rather than trying to enter both markets simultaneously. The listing infrastructure, visual assets, and content architecture established in the U.S. can be largely reused for the EU launch.

Roadmap — At a Glance

Frequently Asked Questions (FAQ)

What is MoCRA?

A law modernizing cosmetics regulations in the U.S. It introduces requirements for facility registration, product listing, safety evidence, and labeling; it also fully applies to foreign manufacturers selling to the U.S.

Does the FDA approve cosmetics?

No. The FDA does not grant pre-approval for cosmetic products; registration and notification requirements under MoCRA are mandatory. The term “FDA-approved cosmetics” is misleading and should not be used in marketing.

Who is responsible for registering a facility for contract manufacturing?

The registration obligation falls on the facility that actually carries out production. The brand owner must clearly distinguish between the contract manufacturer’s registration and its own product listing notifications.

Is Amazon subject to cosmetic product approval (gated) in the U.S.?

The category is generally open; however, for certain product groups (such as lighting or products making stain-resistant claims), Amazon may request a test report or documentation. Claims made in the listing text are also reviewed.

Can the label include a list of ingredients in Turkish?

No. The list of ingredients must be in INCI format, and the entire label must be in English.

Can I sell to the EU using the same records?

No. The EU has its own set of rules: topics such as the responsible person, CPNP notification, EORI, VAT, and GPSR operate independently of the U.S. It is better to plan for the two markets sequentially.

Findings from This Case

• 1. The local test serves as a trial run for the U.S. market. Using real PPC and conversion data from Amazon Turkey directly improves the quality of decisions made for the U.S. launch.
• 2. The regulatory layer must be established before the launch. MoCRA facility registration, US Agent designation, product listing, and INCI compliance are tasks that must be completed prior to listing preparations, not in parallel with them.
• 3. A niche approach can yield results faster than the mainstream category. Visibility in highly competitive markets is expensive; starting with a differentiated product is a more cost-effective way to build brand awareness.
• 4. The language used in the claims must be carefully crafted from the start. Even a single sentence that crosses the line between cosmetics and pharmaceuticals can lead to the listing being removed; the content team and the compliance team need to work closely together.
• 5. The U.S. and the EU are separate projects. Trying to establish two sets of rules at the same time divides attention; proceeding sequentially also makes it possible to reuse the content infrastructure established in the U.S. in the EU.

If you’re planning to enter the U.S. market with your cosmetic products, Export Partners is here to support you every step of the way through the FDA registration and certification processes, as well as the trademark registration process in the U.S.