Lotions, balms, scrubs, and cosmetic-grade soap for direct sale in Iowa
Under the Modernization of Cosmetics Regulation Act, anyone manufacturing or processing cosmetics for U.S. consumers — including farmers market and online sellers — registers their facility with FDA and lists each product, renewing every two years.
Keep a written safety file per formula: ingredient review, exposure assessment, and confirmation the product isn't adulterated. This requirement applies to every business size — there is no small-business exemption from it.
Businesses averaging under $1,000,000 in annual U.S. cosmetic sales over three years can skip formal Good Manufacturing Practice audits and some registration/listing timing, but only for lower-risk products — talc, injectables, and a few other categories are carved back out.
| Item | Rule | Regulator |
|---|---|---|
| Facility registration | Register with FDA; renew every 2 years | FDA (MoCRA) |
| Product listing | List each product and its ingredients with FDA | FDA (MoCRA) |
| Safety substantiation | Written safety file per formula; no size exemption | FDA (MoCRA §608) |
| Adverse event reporting | Report serious adverse events to FDA within 15 business days | FDA (MoCRA) |
| True soap (lye-saponified, no cosmetic claim) | Regulated as a consumer product, not a cosmetic | CPSC |
Only if it's true soap — made by saponifying fats with lye and sold purely as soap, with no lotion-like or skin-treatment claims. Add a moisturizing or anti-aging claim and it becomes a cosmetic under MoCRA.
No separate Iowa state cosmetics license exists for handmade body care; MoCRA is the primary framework, though your city or county may require a general business license.
It can relieve you from formal GMP recordkeeping and some registration/listing deadlines, not from safety substantiation or adverse event reporting — those apply to everyone.
You can, but keep the operations and licensing separate in your paperwork — cosmetics fall under MoCRA/FDA while foods fall under Iowa's cottage food or food establishment rules, and a shared workspace needs to satisfy both sets of standards.