Why Cosmetic Ingredient Names Matter and What MOCRA Really Means - Interview with Heather Bustos

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 existThe Personal Care Products Council and how INCI naming worksHow ingredient naming crosses into marketing strategyReal-world examples of label creativity and regulatory riskMaking sense of MOCRA — what’s live, what’s stuckWhy registration, adverse event reporting, and safety substantiation matter nowWhat we still don’t know about cosmetic GMP enforcementGMP audits vs desk compliance — why experience mattersU.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 strategyWhat’s actually required vs what’s still vague in cosmetic regulationHow the naming process works with industry groupsHow MOCRA changes the compliance landscapeReal compliance lessons from factory audits

Resources Mentioned

Personal Care Products CouncilMOCRA (Modernization of Cosmetics Regulation Act)Cosmetic registration and listingAdverse event reporting basics

Who This Is For

Cosmetic brand owners and foundersIngredient suppliers and formulatorsRegulatory affairs professionalsLegal and compliance teamsAnyone 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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