AIM Global Submits Comments on Cosmetics Records Access

Advocates for Recognition of AIDC Technologies in FDA Guidance for Industry

Pittsburgh, PA, March 26, 2026 – AIM Global, the leading international industry association, global authority and resource in automatic identification and data capture (AIDC) technologies and innovations including barcode, biometrics, IoT, NFC, RFID, RTLS, and RAIN, announced that its Board of Directors has approved formal comments submitted in response to U.S. Food and Drug Administration Docket No. FDA-2025-D-2243, Draft Guidance for Industry: “FDA Records Access Authority for Cosmetics.

The comments were developed through discussions within AIM’s Visibility Technologies Industry Group after Connie Nguyen, Strategic Business Development at MAXIM Group, raised the importance of the Modernization of Cosmetics Regulation Act of 2022 (MoCRA)and its implications for supply chain visibility and traceability.

“MoCRA is not just a regulatory update. It is the most significant shift in U.S. cosmetics regulation in over 85 years,” said Nguyen. “Visibility is no longer optional. It is essential.”

AIM’s submission supports FDA’s overall approach and encourages the agency to more explicitly recognize that relevant records may include machine-readable traceability data generated through barcode systems, RFID, serialized product identifiers and interoperable digital traceability systems used across today’s cosmetics supply chain ecosystem.

“As cosmetic supply chains undergo digital transformation, it is critical that the FDA’s final guidance acknowledges that records are increasingly generated and maintained through modern identification and traceability systems.” said Mary Lou Bosco, CEO of AIM Global. 

Read AIM Global’s full comments HERE