Missouri Direct-to-Consumer Guide 04 of 24

Body Care

Soaps, lotions, balms and scrubs

Federal Rules Apply
MoCRA2022 federal cosmetics law
$1MSmall-business threshold (3-yr average)
SoapTrue soap is outside cosmetics
0Missouri cosmetic license identified

What is covered, and what needs a different path

Covered

  • True soap labeled only as soap
  • Lotions and balms with substantiated safety
  • Small businesses under the MoCRA threshold

Needs a different path

  • Drug claims such as treats eczema
  • Eye-area, injectable or internal products (no small-business relief)
  • Unlabeled or unlisted products over threshold

Three compliance steps

A

Sort soap from cosmetics

Only cleansing products made from fats and alkali and sold as soap escape cosmetic rules.

B

Check the small-business exemption

Under the threshold you skip facility registration and product listing, but safety substantiation and labeling still apply.

C

Label and report

Ingredient list, domestic contact, and a process for adverse event reports.

Quick reference

ItemRuleRegulator
SoapOutside FDA cosmetic definition if cleansing onlyFDA / CPSC
Lotion or balmCosmetic: labeling and safety substantiationFDA
RegistrationSmall businesses generally exemptFDA
Drug claimsTreat or cure claims make it a drugFDA
Sales taxRetail sales are taxable; Missouri sales tax license, state plus local rateMO DOR

FAQ

Do I register with FDA?

Not if you qualify as a small business and make no excluded product types.

Do I need a Missouri license?

None specific to cosmetics was identified.

Can I claim a product heals?

No. Therapeutic claims create drug obligations.

Printable checklist

  • Classify: soap or cosmetic
  • Check small-business threshold
  • Write safety substantiation file
  • Label with ingredients
  • Set adverse event process
  • Register for sales tax