Does a private label SPF moisturizer need to be made in an FDA-registered facility?

Yes. In the United States, any product with an SPF claim is classified as an OTC drug, not a cosmetic. The manufacturing facility must be FDA-registered as an OTC drug establishment. Always request the facility's registration number and confirm it appears in the FDA's active database. AJ Cosmo Labs pre-vets manufacturers on the platform for OTC facility compliance.