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What this covers They are cosmetics Until one sentence moves them The classification is not in the jar No approval, and no shelter either What the label has to carry And one warning most makers have never read The containers vary more than the recipes References

Nothing here needs FDA approval before you sell it. You are the one responsible for it being safe and correctly labeled, and that is a different thing from being unregulated.

What this covers

Beard oil, pre shave oil, beard balm, mustache wax, beard butter, shave cream, shave soap and aftershave. Eight products that a small maker can start with a scale, a double boiler and a bench, and that sell to the same customer.

They are cosmetics

All eight are articles applied to the body for cleansing, beautifying, promoting attractiveness or altering the appearance, which is the statutory definition of a cosmetic. That is the easy half.

Until one sentence moves them

A drug includes an article intended to affect the structure or any function of the body. A beard oil that conditions a beard is a cosmetic. The same oil sold as making the beard grow is intended to change what the body does, and that is a drug.

The classification is not in the jar

FDA establishes intended use from claims, from consumer expectations and from certain ingredients. Two identical bottles can be classified differently because of what the label and the website say about them, which means the regulatory decision is made by the copywriter.

No approval, and no shelter either

Cosmetics and their ingredients, color additives aside, do not need FDA approval before sale. Making them at home is not against the law. What you carry instead is the obligation that the product is not adulterated and not misbranded, and both of those are things you can fail by accident.

What the label has to carry

An ingredient declaration in descending order of predominance, a name and a street address, and a net quantity of contents in a specified place on the panel at a specified type size. Four requirements, and each has a regulation behind it rather than a convention.

And one warning most makers have never read

A cosmetic whose safety has not been adequately substantiated has to carry, on the principal display panel, the words "Warning--The safety of this product has not been determined." Substantiating safety is what makes that sentence unnecessary.

The containers vary more than the recipes

An oil wants a narrow neck and a dropper. A balm wants a wide mouth you can get two fingers into. An aftershave is high alcohol and goes in glass. One craft, four genuinely different shelves, which is why the container section here is longer than it is for most products.

References

FD&C Act section 201(i), the cosmetic definition: articles "intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to the human body... for cleansing, beautifying, promoting attractiveness, or altering the appearance". fda.gov

FD&C Act section 201(g)(1), the drug definition, in part: "articles intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease" and "articles (other than food) intended to affect the structure or any function of the body of man or other animals". fda.gov

FDA, Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?). Whether a product is a cosmetic or a drug is determined by its intended use, and intended use is established by factors including product claims, consumer expectations, and certain ingredients. A product can be both at once, as an antidandruff shampoo is. fda.gov

FDA, Small Businesses & Homemade Cosmetics: Fact Sheet. Cosmetics and their ingredients, other than color additives, do not need FDA approval before sale, and the manufacturer is "legally responsible for making sure your cosmetics are safe and properly labeled". Manufacturing at home is not against the law, but the product must not be adulterated by the conditions it is made in. fda.gov

21 CFR 740.10, the warning for a cosmetic whose safety has not been adequately substantiated, which must appear on the principal display panel: "Warning--The safety of this product has not been determined." law.cornell.edu

Written from the FD&C Act and 21 CFR parts 701 and 740, and from the catalog as it stood on 17 October 2026. Whether a particular product is a cosmetic or a drug turns on its claims and its ingredients, and that determination has consequences; nothing here substitutes for getting it right for a specific formula and a specific label.