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Is RevivHair a cosmetic or a drug?

Written By: The Serum Guru

RevivHair is a cosmetic. As a cosmetics company, we are legally bound by U.S. FDA rules and regulations. And the FDA's definition of a cosmetic: a product that is "for cleansing, beautifying, promoting attractiveness, or altering the appearance" and does not "affect the structure or any function of the body" which would make the product a "drug."

When developing products we often have to walk a fine line when it comes to formulating for efficacy and marketing claims. We cannot say that, for instance, a product "will grow hair." We have to be very specific about terminology. In fact, in general we don't use any specific claims for a particular product. Any claim verbiage we use is strictly related to the individual raw ingredients we utilize, and we use only major manufacturer data -- who are also under U.S. FDA regulations about what they can claim and what they cannot. Our manufacturer claim data is legitimate, bonafide, and accurate (and googleable).

So while we of course cannot say that RevivHair will "grow hair," we can say it may very well help provide the optimal environment for strong, healthy, thick hair. That may sound like marketing gobbledygook, but it's the law.

But what about "cosmeceuticals?" Aren't they a "drug?" From our colleagues at The Chemist Corner:

One other classification of products is cosmeceuticals. The oft-controversial but significant contributor to our field, dermatologist Dr. Albert Kligman, coined the term cosmeceutical almost 30 years ago. He defined cosmeceuticals as topically applied products that do have a physiological effect on the skin. The industry was quick to respond because the potential regulation of cosmetics as drugs could cripple innovation due to time and cost. Kligman, however, intended to draw attention to the potential biological effects of all cosmetics that did not just merely camouflage or add color. In fact he said it was “scientifically silly to pretend that cosmetics did not do anything” and that cosmetics might actually be doing a lot of good.

The term cosmeceutical is not recognized as part of the Federal Food, Drug, and Cosmetic Act. But whether you agree or disagree, this term has become part of our consumer’s vernacular. The controversy and conversation the term has created remains, in my mind, one of Kligman’s great contributions to cosmetic science.


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