If your patch label makes a drug claim — such as 'treats acne' or 'unclogs pores' — and contains salicylic acid at 0.5–2% USP, the FDA classifies it as an OTC drug under the acne monograph. A cosmetic claim like 'absorbs impurities' keeps it cosmetic. Your formulator should advise on this distinction early to avoid costly reformulation or labeling changes.
Read the full guide on how to find a cosmetic chemist for acne patch formulation →