I know there are some exceptions regarding registration of all products (Beside the 24h rule) if the sales are lower than $1m pr. year. Is these sales looked at as a the sales inside the US or as in our case we are based in Europe and sell to a wholeseller in the US, so the amount we sell for to this wholeseller? Hope it makes sense...
MoCRA defines small business as facilities, whose average gross annual sales in the United States of cosmetic products for the previous 3-year period is less than $1,000,000, adjusted for inflation. Our interpretation is that the sales apply to products that are sold in the US. In your case, you would need to consider the sales of cosmetic products you sell in the US through your wholesaler.
I do not care for one category of FDA-regulated US cosmetics and prefer products purchased online in foreign markets. Is this going to get in the way of me being able to buy from foreign manufacturers who don’t have a presence in the US but offer shipping to the US?
I know there are some exceptions regarding registration of all products (Beside the 24h rule) if the sales are lower than $1m pr. year. Is these sales looked at as a the sales inside the US or as in our case we are based in Europe and sell to a wholeseller in the US, so the amount we sell for to this wholeseller? Hope it makes sense...
MoCRA defines small business as facilities, whose average gross annual sales in the United States of cosmetic products for the previous 3-year period is less than $1,000,000, adjusted for inflation.
Our interpretation is that the sales apply to products that are sold in the US. In your case, you would need to consider the sales of cosmetic products you sell in the US through your wholesaler.
@@CewayEu if there are multiple locations representing a single brand, is the $1M applied to each location or in aggregate?
@@seangommier8652 the legislation says per business. I would presume that this would mean in aggregate, but it's not really clear
@@CewayEu glad you're in agreement on the ambiguity. It's quite frustrating that this legislation has been passed without more clear guidance.
I do not care for one category of FDA-regulated US cosmetics and prefer products purchased online in foreign markets. Is this going to get in the way of me being able to buy from foreign manufacturers who don’t have a presence in the US but offer shipping to the US?