The PIF, held continuously
The Product Information File assembles continuously and stays retained ten years after the last batch placed on the market, instead of being pulled together under pressure.
• Cosmetics
The PIF stays current instead of being assembled under pressure. Ingredient restrictions are checked against live annexes, and registration clocks run on their own.
Supported frameworks, not certifications. Regulatory updates included.
Why now
MoCRA lets the FDA write a cosmetic manufacturing practice rule. It is not published yet, but the rest of MoCRA is already enforced.
Facility registration, product listing, safety substantiation and serious adverse event reporting.
Since September 2025, reports are searchable by product name.
It carries a presumption of conformity in the EU. India’s Schedule M-II is thinner, so Factro treats it as a subset.
What is tailored
Where the Cosmetics pack changes how the core behaves.
The Product Information File assembles continuously and stays retained ten years after the last batch placed on the market, instead of being pulled together under pressure.
Retained samples are tracked as inventory, with location, quantity and parent batch, not a shelf someone remembers.
Ingredient restriction checking runs against live annexes, flagging every affected formulation the moment a substance is added.
Built for cosmetics
These features switch on with the cosmetics pack, on the same record as production and quality.
01 / Controlled documents · Formula revisions
Each formula revision goes through review and approval before it takes effect. Operators work from the effective revision, and every batch links to the revision it ran on.
A new revision runs through change control, review and approval. Until it takes effect, the line keeps the current one.
When a revision takes effect the earlier one is superseded, and training on it is reassigned to the people who use it.
Each batch links to the revision it ran on, so an investigation starts from the right formula.
02 / Library · Registrations and labelling
Each product keeps its permissions, registrations and labelling requirements by market, on the catalog record. The Product Information File draws on the same record instead of a folder.
Licences, notifications, listings and registrations sit on the product with their validity, market by market.
Each registration renews on its own date, and regulatory affairs is alerted with time to act, not after it lapses.
The Product Information File draws on the same record and is retained ten years after the last batch placed on the market.
03 / Inventory · Retained samples
Retained samples are logged at release with a location, quantity and parent batch. Every pull is recorded, and alerts come as a sample nears the end of its retention period.
Each sample is logged at release with its cabinet, shelf, quantity and parent batch, not a shelf someone remembers.
Taking a sample for a complaint or a test lowers the quantity and keeps the reason on its history.
Samples nearing the end of their retention period are flagged, so disposal is planned with QA.
04 / Quality · Ingredient restrictions
Ingredient restrictions are checked against live annexes. When a substance is added or restricted, every affected formulation is flagged for review, with its level beside the limit.
Restrictions come from the annexes in force, from EU Regulation 1223/2009 to IS 4707, not a list copied last year.
An annex update flags each formulation that uses the substance, so nothing waits for someone to remember it.
Each flag goes to an owner for review, and a reformulation runs through change control like any other revision.
India licensing, built in
The pack holds the licence register, the renewal clocks and the Schedule M-II batch record fields inspectors review first.
Granted within 45 days. Perpetual after that, with a five-yearly retention fee.
The registration certificate that covers imports.
Valid for three years, with the renewal on its own clock.
Needed before the ingredient is first used in a formulation.
Controls
Every control below runs on the Compliance Engine. The same record carries the evidence across the plant.
Also mappedISO 11930:2019
Append-only, hash-chained audit trail capturing old value, new value, author, time and reason
Product Information File assembled continuously, retained ten years after the last batch placed on the market
Ingredient restriction checking against live annexes, flagging every affected formulation when a substance is added
Batch manufacturing records in the Schedule M-II shape, carrying quantity required against quantity actually used
Retained samples tracked as inventory, with location, quantity and parent batch
Stability and challenge testing results bound to the shelf life and period-after-opening claim
Preservative efficacy testing to ISO 11930, with results attached to the formulation version
Role-based access control, down to the individual field
Segregation of duties enforced in the system, maker is never checker
Change control across formulation, supplier, process and label
Internal audit scheduling with findings routed to CAPA
Out of specification handling with investigation and disposition
Complaints and recall procedure with classification and effectiveness checks
Subcontracting control with written scope and qualification records
Training tied to document version, reassigned on every revision
Regulatory change
The Compliance Engine tracks the rules that apply to you, works out what a change touches, updates the system and re-validates before release. You file no change request.
The regulation became fully applicable, introducing the responsible person, the Product Information File and cosmetic product safety reports.
The Modernization of Cosmetics Regulation Act gave FDA new authority over facility registration, product listing, safety substantiation and mandatory recall.
MoCRA adverse events became searchable by product name; the pack's serious adverse event intake already ran on the 15-business-day clock it needed.
Facility registration on a two-year renewal, annual product listing, safety substantiation, serious adverse event reporting and FDA mandatory recall authority.
Replaced the 2017 prohibited and restricted ingredient standard in India. Part 3:2025 on permitted preservatives took effect 9 August 2025.
Non-compliant stock had to be off the market.
Carrying new CMR classifications and recent scientific committee opinions.
Validation readiness
Available on the Dedicated tier, mapped to your workflows. URS, IQ, OQ, PQ, RTM and GAMP 5.
Certification in progress. Encryption, access control and backups are described on Security & Trust.
The Compliance Engine scores inspection readiness continuously, with guidance on each open gap.
Make it your workflow
Bring the regulation that keeps you up at night. We will show you the control that answers it, on a batch from your plant.