Is retinol in eye creams regulated differently by the FDA?

In the US, retinol eye creams are classified as cosmetics — not OTC drugs — as long as label claims are cosmetic in nature. However, the EU restricts retinol to 0.3% in eye-area products, and California's Prop 65 may require a warning at higher concentrations. MoCRA (2023) also requires US facility registration. Your manufacturer should guide you through all applicable compliance steps.