Lot tracking for cosmetics means every unit can be traced to its batch and every batch to its customers. It is the foundation of recall readiness and the reason established beauty brands choose a specialist.
What MoCRA changed for beauty logistics
The Modernization of Cosmetics Regulation Act of 2022, known as MoCRA, was the largest update to U.S. cosmetics law since 1938. It requires the responsible person for a cosmetic product, usually the brand owner, to list products with FDA, substantiate product safety, keep records of adverse events and report serious adverse events to FDA within 15 business days. It also gave FDA mandatory recall authority over cosmetics.
MoCRA does not make your 3PL the responsible person, and in general facility registration applies to establishments that manufacture or process cosmetics rather than those that solely hold or distribute them. But the law raised the stakes for traceability. If FDA or your quality team needs a product pulled, you need to know which batches went where, quickly.
That is the job of lot tracking in the warehouse: to make your regulatory obligations practical to meet.
Lot and expiry captured at receipt
Lot control starts at the dock. When inventory arrives, we record batch or lot code and expiration date for each receipt, and where products carry a period-after-opening symbol or manufacture date instead of an expiry, we record what you specify as the controlling date.
If a supplier ships mixed lots on a pallet or in a carton, each lot is counted and located separately. Discrepancies between your advance shipping notice and what arrives are reported the same day, so you can resolve them with your manufacturer while the details are fresh.
From that point forward, every location, movement, pick and shipment carries the lot record. Cycle counts verify lot as well as quantity, so inventory accuracy covers the information that matters most in a recall.
FEFO picking and quarantine holds
First-expired, first-out picking directs pickers to the lot closest to expiration that is still eligible to ship. You define eligibility: a minimum remaining shelf life for DTC, a longer minimum for retail, and rules for marketplaces such as Amazon that publish their own expiration-date requirements.
Lots that cross a threshold are moved to a hold status automatically and reported, so short-dated inventory becomes a planned decision instead of a surprise. You can release it to a discount channel, use it for sampling, donate it or schedule documented destruction.
Quarantine holds can be placed on any lot at any time. When a lot is held, it stops shipping across all channels and markets immediately, while existing stock remains counted and visible for your investigation.
Recall-ready reporting on demand
Recall readiness is the payoff. For any lot, we can report every order, customer, retail purchase order and distribution center that received it, with ship dates and quantities. Reports can also run in reverse, showing every lot a given customer or store received.
This turns a recall from a brand-wide pull into a targeted action. Your team can contact only affected customers, notify only affected retail partners and leave unaffected batches on sale.
We also maintain records of inventory adjustments, holds, releases and destructions with dates and quantities, giving your quality and regulatory team the documentation they need. Mock recall exercises can be scheduled so you can test the process before you ever need it.
What's included
- Batch and expiry capture at receipt
- Lot-level cycle counting
- FEFO with per-channel shelf-life minimums
- Automatic short-dated holds and alerts
- Instant quarantine across all markets
- Lot-to-order and lot-to-PO recall reports
- Mock recall exercises on request
Frequently asked questions
Is a cosmetics 3PL required to register with FDA under MoCRA?
Generally no. MoCRA facility registration applies to establishments that manufacture or process cosmetics, and the statute excludes establishments that solely label, relabel, package, repackage, hold or distribute. Brands should confirm their own obligations with regulatory counsel.
Who is responsible for MoCRA adverse event reporting?
The responsible person, typically the brand whose name appears on the label, must report serious adverse events to FDA within 15 business days. We support that work with lot and shipment data.
What if my products have no expiration date?
Many cosmetics carry a batch code and a period-after-opening symbol rather than an expiry. We record the lot and whatever controlling date you specify, such as manufacture date plus shelf life.
How fast can you produce a recall report?
Lot-to-order reports come directly from our warehouse system, so affected orders and retail shipments can be identified on request rather than reconstructed from spreadsheets.