Regulatory Open Forum

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  • 1.  Regenerate skin....A Cosmetic or drug claim?

    Posted 18-Oct-2017 19:07
    Colleagues,

    One of the masks that we are launching has a claim that it has an excellent regenerating skin effect.  I know that to claim regeneration at the cellular level is an issue, but was not sure if the aforementioned skin regeneration claim would be considered a drug as opposed to a cosmetic claim. I suppose that could be considered somewhat like exfoliation or perhaps it would have made a difference if they said "Skin cell regeneration"?

    Please advise.

    Cheers,
    Laura

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    Laura HoShue
    Regulatory Compliance Specialist
    Las Vegas, Nevada
    USA
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  • 2.  RE: Regenerate skin....A Cosmetic or drug claim?

    Posted 19-Oct-2017 08:50
    ​Hi Laura.

    Simple answer is that a regenerative claim is almost certainly going to be looked at as a drug claim.  There really isn't much you can do to fix that because it is obviously going to fall into either a "structure-function" effect or will fall under a skin growth effect - both of which are generally considered drug claims.

    That said, there may be some gray area in the requirements if you were to reword the claim in such a way as to avoid making such a strong claim statement here.  Feel free to contact me to discuss further if you would like!

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    Victor Mencarelli
    Director - Regulatory Affairs
    Hain Celestial Group
    United States
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  • 3.  RE: Regenerate skin....A Cosmetic or drug claim?

    Posted 20-Oct-2017 11:40
    Hello Victor,

    You are such a great resource and your feedback is always so informative and concise.  I too thought it would be a claim that is viewed as one that affects structure, but thought it best to confer with more seasoned colleagues like yourself.

    Once again, thank you and I will be sure to reach out to you.  :)


    Regards,
    Laura

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    Laura HoShue
    Regulatory Compliance Specialist
    Las Vegas, Nevada
    USA
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