Skin Care Products - Cosmetics or Drugs? 

Often, they are both… but how can you tell? Or do you even need to? Here’s how skin products are classified in the US, but many countries have similar regulations. Government health and consumer protection regulations require products to be labelled appropriately - and they also understand that sometimes a product can be both a cosmetic and a drug.

According to the FDA: Cosmetics are "articles intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body...for cleansing, beautifying, promoting attractiveness, or altering the appearance". Drugs are "articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease" and "articles (other than food) intended to affect the structure or any function of the body of man or other animals."

Whether a product is a cosmetic or drug depends on its “intended use” (basically, what the manufacturer says it's for). For example, if it’s to clean or moisturize your skin, it’s a cosmetic, but if it’s to treat your acne or provide sun protection, it’s a drug. Both are regulated, but skin care products with drugs are more carefully regulated.

Checking the ingredient list can help you know which is which. The FDA says, “drug ingredients must be listed alphabetically as "Active Ingredients," followed by cosmetic ingredients, listed in order of importance as "Inactive Ingredients."

What about plain old soap? Even this has a definition. In older times people made soap by mixing ashes, water and fat.  The resulting chemical reaction produced slippery bars of “alkali salts of fatty acids” the FDA’s primary definition of soap. Soap is regulated as a consumer product.  If you add moisturizers or fragrances, soap becomes a cosmetic. If you add antibacterial cleansers, soap can also be a drug.

Some products step close to the line in their labels or their claims. Bad behaviour can include a common active ingredient being listed under “Ingredients” because it is present at such a low concentration to be inactive (and therefore ineffective). Other products will sidestep regulations by saying customers “felt” an improvement after using a product, instead of saying that the product produced an improvement.

So, check the ingredients list on your products and what the product says it does. If you see “active ingredients” your product is regulated as a drug. If it just says “ingredients” it is a cosmetic (or soap). If it claims to treat, heal or repair, it’s a drug. If it claims to just cleanse, moisturize or cover then it is a cosmetic.


1.     USFDA; Is It a Cosmetic, a Drug, or Both? (Or IsIt Soap?)

2.     Health Canada; Classification of Products at theCosmetic-Drug Interface