In the US, a toner containing 0.5–2% salicylic acid marketed for acne is classified as an OTC drug under the FDA acne monograph, requiring drug facts labeling and specific usage directions. AHA-only exfoliating toners are cosmetics but must display a sun-sensitivity warning. A cosmetic chemist sourced through AJ Cosmo Labs can guide you through the correct regulatory pathway for your specific formula.
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