§605 Serious Adverse Event Reporting

MoCRA (Modernization of Cosmetics Regulation Act) requires the responsible person to triage cosmetic complaints, decide whether cases are serious, and file reports with the FDA (Food and Drug Administration) within 15 business days.

Key obligations

  • Log every complaint from consumers, retailers, health-care providers, and social media.
  • Escalate potential serious cases to a medical reviewer the day they arrive.
  • Submit FDA Form 3500A (with a label image) for each confirmed serious adverse event within the 15-day window.
  • Send follow-up reports when new medical information arrives within one year.

Evidence regulators expect to see

  • Complaint intake log showing timestamps, severity, and actions.
  • Escalation ladder that names medical reviewers and regulatory approvers.
  • Copies of FDA submissions and acknowledgement emails.
  • Retention proof that complaint files stay on record for at least 6 years (3 for small businesses).

Intake sections that populate this section

Relevant SOP templates

Risk of non-compliance

  • FDA warning letters for late or missing submissions.
  • Civil penalties or injunctions if serious events stay unreported.
  • Retailer penalties and loss of shelf space during investigations.

Further reading

Use these notes to brief leadership and justify remediation work. As you complete the intake, the Generate Package step merges your answers into each SOP so you can demonstrate compliance with §605 Serious Adverse Event Reporting.