Georgia · Direct-to-Consumer Compliance · Category 04 of 24

Body Care

Soaps, lotions, balms, and skincare products sold direct to consumer under federal cosmetic rules

General Consumer Product

None

GDA License

FDA (MoCRA)

Federal Agency

Only if 'cosmetic'

Facility Reg.

Exempt from FDA cosmetic rules

True Soap

What's Covered / What Needs More

✓ Generally Covered

True lye-based soap sold as 'soap' with no cosmetic claims (cleansing only) — regulated by CPSC, not FDA cosmetics
Lotions, balms, and scrubs sold with cosmetic claims (moisturizing, cleansing, beautifying)
Selling direct at markets, online, and to retail stores with no GDA license
Registering as a facility under the federal Modernization of Cosmetics Regulation Act (MoCRA) if selling cosmetic-claim products

✕ Needs More / Watch Out

Skipping MoCRA facility registration and product listing if your product makes a cosmetic claim (moisturizes, cleanses, beautifies skin) and you're not a below-threshold small business exempt
Drug claims (acne treatment, anti-aging 'reverses wrinkles', SPF/sunscreen claims) without FDA drug-level compliance
Ignoring allergen and INCI ingredient labeling expected by retailers and required for cosmetics
Assuming Georgia has its own separate cosmetic license — it defers to federal FDA rules

Three Steps to Compliance

Classify: soap vs. cosmetic

If your bar soap only cleans (no moisturizing/beautifying claim) and is made of alkali + fat, it's regulated as 'soap' under CPSC, not as an FDA cosmetic — the simplest path.

Register under MoCRA if cosmetic

Lotions, balms, and any skin product with a cosmetic claim generally require facility registration and product listing with FDA under the 2022 Modernization of Cosmetics Regulation Act, phased in through 2024–2025 with ongoing small-business provisions.

Label and sell freely in Georgia

No GDA license applies to body care. Georgia sales tax ID and local business license are your only state-level requirements; sell at markets, online, or wholesale without restriction.

Quick Reference

GDA license required?	No — body care is not food or feed
Federal oversight	FDA cosmetic rules (MoCRA) if cosmetic claims are made
True soap (cleansing-only claim)	Regulated by CPSC, exempt from FDA cosmetic rules
Facility/product registration	Required under MoCRA for cosmetic-claim products (small-business exceptions apply)
Retail/wholesale	Allowed with no state permit
Biggest risk	Making drug-level claims (treats acne, anti-aging, SPF) without FDA drug compliance

Frequently Asked Questions

Do I need a Georgia license to sell homemade soap?

No — true soap (cleansing only, no cosmetic claim) has no GDA or state cosmetic license requirement.

What changed with MoCRA?

The federal Modernization of Cosmetics Regulation Act (2022) now requires many cosmetic manufacturers to register facilities and list products with FDA — check current small-business thresholds before assuming exemption.

Can I say my lotion 'moisturizes'?

Yes, that's a standard cosmetic claim — just be sure you've handled any applicable MoCRA registration/listing.

Can I say my balm 'heals eczema'?

No — that's a drug claim requiring FDA drug-level review, which is well beyond the general body-care path.

Printable Checklist

Classify product as true soap or cosmetic
Check current MoCRA facility/product registration requirement
Ingredient list in INCI format
Net weight and business name/address on label
No drug or disease-treatment claims anywhere
Georgia sales tax ID and local business license in place

MarketStand · Georgia Producer Compliance Series

This guide is general information, not legal advice, current as of September 2026. Georgia's cottage food, meat inspection, dairy, egg, plant, feed, and alcohol rules change — always verify current requirements with the Georgia Department of Agriculture (agr.georgia.gov), Georgia Dept. of Revenue Alcohol & Tobacco Division, and your local health department before selling.

Primary sources: Georgia Dept. of Agriculture (Cottage Food, Meat Inspection, Egg Law, Live Plant Program, Feed/Pet Food Program); HB 398 (2025); Georgia Raw Dairy Act, O.C.G.A. §26-2-450 et seq.; Georgia Meat Inspection Act, O.C.G.A. §26-2-60; Georgia Food Act, O.C.G.A. §26-2-20; GA Dept. of Revenue Alcohol & Tobacco Division; FDA (DSHEA, MoCRA, FSMA Produce Safety Rule, 21 CFR 108/111/113/114).