OK, let’s get right down to it – your skin care products may contain ingredients that are actually classified as OTC’s. OTC stands for “over-the-counter” and refers specifically to non-prescription drugs. This isn’t necessarily a problem, although any skin care product containing an over-the-counter drug needs to be labeled as such. This may be a bit of a “gray area”, as you’ll see.
Before we shed light on the labeling dilemma, let me give you some technical detailing set forth by the U.S. Food and Drug Administration (FDA) and it’s corresponding Food, Drug and Cosmetic Act (from now on referred to as “FD&C Act”) which sets definitions and protocols for our industry.