AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Under the Modernization of Cosmetics Regulation Act (MoCRA), the Nigerian factory that makes a hair cream, oil, pomade or relaxer for the US must register with the FDA and renew every two years, and the "responsible person" named on the label must list each product and its ingredients and update the listing every year. The FDA issues no approval or certificate. Hair products that claim to treat hair loss or dandruff can be drugs, with stricter rules.
Cosmetic, drug or both
The first question is not paperwork but classification. The FDA's page "Is it a cosmetic, a drug, or both?" explains that the answer depends on a product's intended use, shown by its claims, and that some products are both. A plain hair pomade or shea-based moisturiser sold to condition and style is a cosmetic. A product sold to regrow hair, stop hair loss or treat dandruff is making drug claims, and over-the-counter drug rules, including an "Active ingredients" panel, then apply. Products that are both list active ingredients first and then the inactive ones.
Import Alert 66-41, for unapproved new drugs promoted in the US, is on the FDA's Nigeria list, so a "growth oil" sold with medical claims runs a real risk of detention. Keep the claims cosmetic unless you are ready for drug compliance.
What MoCRA requires
| Duty | Who | Detail |
|---|---|---|
| Facility registration | the facility that manufactures or processes the product, in Nigeria or elsewhere | register with the FDA and renew every two years from the initial registration |
| Product listing | the responsible person, whose name is on the label | list each product with its ingredients; update the listing every year |
| Serious adverse events | the responsible person | report to the FDA within 15 business days, with a copy of the label |
| Safety substantiation | the responsible person | keep records showing the product is safe |
| Certificates | nobody | the FDA does not issue registration certificates for cosmetics |
Registration and listing are done through the FDA's Cosmetics Direct portal or its electronic submissions gateway, using Forms FDA 5066 and 5067; FDA says setting up a gateway account can take one to three weeks. The registration number the FDA assigns is the facility's FEI number. Anyone offering an "FDA certificate" for a cosmetic is selling something the FDA does not issue.
Who is the responsible person
MoCRA defines the responsible person as the manufacturer, packer or distributor whose name appears on the label. If you import a Lagos brand under its own name, it is the responsible person and must list the products. If you sell it under your US company's name as distributor, that duty is yours. Agree in writing who does what before the first order.
The small business exemption
MoCRA exempts certain small businesses from registration and listing. We did not confirm the current sales threshold on the FDA pages we read, so check it before relying on it. The exemption does not cover products that regularly contact the mucous membrane of the eye, are injected, are for internal use, or are meant to alter appearance for more than 24 hours under customary use; some hair colouring or straightening products may fall in that last group, so check with the FDA guidance.
Colours and soap
Import Alert 53-06, for cosmetics adulterated or misbranded because of colour additive violations, is listed for Nigeria. Colour additives in US cosmetics must be ones the FDA permits for that use, so ask your supplier for the exact colourants in tinted pomades and gels.
Black soap is a special case. Under 21 CFR 701.20, a product whose bulk is an alkali salt of fatty acids and which is labelled and sold only as soap is regulated as soap by the Consumer Product Safety Commission, not as a cosmetic. Add moisturising or skin claims and it becomes a cosmetic. See selling black soap in the US and importing shea butter as a cosmetic.
Worked example: a hair oil range
Example: a Houston distributor imports three products from an Abeokuta maker: a hair oil, a leave-in cream and an edge gel, all sold under the distributor's own brand. The Abeokuta factory registers as a facility and receives an FEI number. The distributor, as responsible person, lists the three products and their ingredients, sets a calendar reminder to update the listings each year, and keeps safety substantiation records, including the maker's formula data. The labels say "conditions and adds shine" rather than "stops breakage and regrows edges", keeping them cosmetic claims. The factory renews its registration two years after the date it first registered.
Steps before importing
- Decide for each product whether it is a cosmetic, a drug or both, based on the claims you will make.
- Agree who is the responsible person and put that name on the label.
- Get the Nigerian facility registered and note the renewal date.
- List each product and its ingredients; diarise the annual update.
- Confirm every colour additive is permitted for its use.
- Set up a way to receive and report serious adverse events within 15 business days.
Where Pryme fits
Hair product makers in Nigeria usually invoice in naira. A Pryme Business Account opened from the US holds USD and NGN with local details, and Swap shows the rate and the fee before you approve. A verifiable receipt from VerifyDoc.ai gives you a record of each payment. See business multicurrency accounts.
Questions people ask
Do Nigerian hair products need FDA approval?
Cosmetics do not need FDA approval, but under MoCRA the manufacturing facility must register and the responsible person must list each product. Hair products with drug claims follow drug rules.
Who registers a cosmetic made in Nigeria with the FDA?
The facility that manufactures or processes it registers. The responsible person named on the label lists the products.
Does the FDA issue a certificate for cosmetics?
No. The FDA assigns a registration number (the FEI) but does not issue registration certificates.
Is a hair growth oil a cosmetic?
If it claims to regrow hair or stop hair loss, it makes drug claims and can be regulated as a drug.
Sources
- FDA: Registration and listing of cosmetic product facilities and products (updated 9 Sep 2026) · accessed Oct 2026
- FDA: Modernization of Cosmetics Regulation Act of 2022 (MoCRA) (content current as of 10 Aug 2026) · accessed Oct 2026
- FDA: Is it a cosmetic, a drug, or both? (Or is it soap?) (11 Sep 2024) · accessed Oct 2026
- FDA: Import alerts by country, Nigeria (posted 21 Oct 2026) · accessed Oct 2026
- eCFR: 21 CFR 701.20, Soap (current text) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.