Beauty salon cosmetics and regulatory question
I have a regulatory question for you – There is a very special type of cosmetics which labeled as : “For professional use only” and it is supposed to be used in beauty salons and almost all of them should really “work” making significant impact on skin structures. I have scrutinized this “salon market” and come to find out that almost all formulations should be OTC. For instance – well known “Nail cuticle removers” – these formulations regularly contain KOH as an active keratolytic. It is obviously affect the structure of the nail unit, cuticles and according to FDA should be declared as OTC drug. However, the companies sell them as the regular cosmetics. So, does the phrase “For salon use only” lets to escape FDA OTC drug registration or are there some other ploys for those products like this? I would be so appreciated for any input you may have. Thank you.
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