Are growth factor serums regulated as cosmetics or drugs by the FDA?

In the USA, they are cosmetics as long as label claims stay aesthetic — e.g., 'visibly reduces fine lines.' Claims implying cellular or structural skin changes (e.g., 'stimulates collagen synthesis') can trigger FDA drug classification under 21 CFR Part 201. AJ Cosmo Labs connects founders with regulatory consultants who specialize in cosmetic claim review before you print labels.