Questions for your situation
What should be checked first on a supplier's “FDA certificate”?
Ask who prepared it and which official procedure it represents. FDA does not issue compliance certificates for cosmetic registration or listing. A private provider's letter is not agency approval. Match facility, product and process with official or verifiable application information before accepting the claim.
Why can different parties hold cosmetic facility registration and product listing duties?
The facility operator and the responsible person named on the label may be different companies. Connect manufacturing contracts, site identity and product information. Assess obligations and any exemptions for each party. One party's registration does not establish assumption of every duty of the other.
Does biennial cosmetic facility renewal automatically update product listings?
Under MoCRA, biennial facility renewal and annual product listing updates are different processes. Track them separately. An unchanged facility does not imply unchanged products. Check the responsible person, formulation and marketed product status against their respective records.
What if the listed device differs from the product covered by a marketing decision?
Compare intended use, device type, models and decision scope. Another similar device's number is not evidence. Determine whether the discrepancy is a record error or a different product or claim. Do not accept the file before the necessary correction or new procedure is clear.
Should registration review examine treatment claims on labels?
Yes. Claims about what the product does can affect US classification and required processes. Drug-type claims on a product presented as a cosmetic require separate assessment. Review labels, website promotion and instructions for the same product. A correct registration screen alone does not establish market conformity.
How should stock from a facility with suspended registration be assessed?
Review the official suspension's scope, product category, facility and market consequences. Trace shipments and stock to that site. Opening another account or appointing an intermediary does not resolve the underlying issue. Document necessary authority procedures and safety measures according to the event.