In the United States, product compliance is not an end-of-project formality: a non-compliant product can be held at import, pulled from sale or rejected by distributors. The rules depend on the product category, and three acronyms keep coming up: FDA, FCC and UL.

Why it is a blocking prerequisite

Three reasons make this a priority. Some obligations apply before the first sale or import. They take time (testing, registrations, labeling), which weighs on the launch schedule. And professional buyers often check them before listing a product.

The right question is not “do I need a standard?” but “which authority covers my product, and what exactly does it require?”.

Cosmetics: what MoCRA changes

Since the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the FDA regulates cosmetics far more closely. It has enforced the registration and listing requirements since July 1, 2024.

  • Facility registration for manufacturing or processing sites, renewed every two years.
  • Listing of every marketed product, including its ingredients, updated annually.
  • A “responsible person”: the manufacturer, packer or distributor whose name appears on the label.
  • Serious adverse events reported to the FDA within 15 business days.
  • Safety substantiation for each product, with records kept; animal testing is not required.
  • A US agent for establishments located outside the country, acting as the FDA’s point of contact.

Certain small businesses are exempt from registration and listing, but not for products that contact the eye, are injected, are for internal use or alter appearance for more than 24 hours.

Food and beverages: registration and prior notice

A facility that manufactures, processes, packs or holds food for consumption in the US must register with the FDA and renew that registration every two years. A foreign facility designates a US agent.

Every shipment of imported food also requires prior notice to the FDA, on top of nutrition labeling rules and, depending on the product, specific requirements (food safety, canned foods, dietary supplements).

Electronics and connected devices: FCC authorization

Nearly all electronic devices must be authorized under FCC rules before they are marketed or imported into the US. There are two procedures:

  • Certification, generally for devices that intentionally transmit a wireless signal: testing by an accredited lab, authorization by a recognized certification body, and an FCC ID.
  • Supplier’s Declaration of Conformity (SDoC), for devices that emit radio frequency only as a by-product of their operation: a lighter procedure, but the responsible party must be located in the US and keep the test results.

A single device may fall under more than one procedure, so each product is assessed on its own.

Electrical products: the real role of UL

UL is one of the laboratories recognized by OSHA under its Nationally Recognized Testing Laboratory (NRTL) program, set up in 1988. The program primarily covers equipment used in the workplace, which must be tested and certified by a recognized lab, and UL is not the only option.

For consumer products, certification by a recognized lab is often required in practice by retailers, insurers or local rules. Check this with your future buyers from the start.

The recommended sequence

  1. Classify the product precisely (category, composition, use, wireless functions).
  2. Identify the competent authorities: FDA, FCC, electrical safety, and state-specific rules.
  3. Budget testing, registrations and lead times, and build them into the launch schedule.
  4. Adapt labels and instructions: English, mandatory statements, contact details.
  5. Appoint your US parties: FDA agent, FCC responsible party, importer.
  6. Take out product liability insurance covering the US market.
Key takeaway

Compliance belongs at the start of the project, not the end. Classify your product, identify the competent authority and budget the lead times before signing with a distributor.

Sources

Information checked on October 23, 2026. Rules change: have your case reviewed by a specialist in the relevant regulation.

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