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Do topical cosmetics need a best buy plan?

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Posted 29 September 2021 - 02:56 PM

This is a bit off topic here, but I was wondering if anyone knew definitively whether topicals/cosmetics needed a best by date.  I see that the FDA doesn't require it unless it is a drug or drug product, but I was unsure if the NSF or other third parties required it (I didn't see anything).  Thank you!


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Posted 13 October 2021 - 05:23 PM





Generally no, unless your product is classified as both a drug and a cosmetic



How does the law define a cosmetic?

The Federal Food, Drug, and Cosmetic Act (FD&C Act) defines cosmetics by their intended use, as "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" [FD&C Act, sec. 201(i)]. Among the products included in this definition are skin moisturizers, perfumes, lipsticks, fingernail polishes, eye and facial makeup preparations, cleansing shampoos, permanent waves, hair colors, and deodorants, as well as any substance intended for use as a component of a cosmetic product. 

How does the law define a drug?

The FD&C Act defines drugs, in part, by their intended use, as "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" [FD&C Act, sec. 201(g)(1)].

Edited by jdpaul, 13 October 2021 - 05:28 PM.

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