A claim moved the product into another regime
Updated
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Hand soap to drug
Antibacterial, antiseptic or kills germs on a hand wash makes it a consumer antiseptic wash, which 21 CFR 310.545 treats as an over-the-counter drug product. The soap did not change; its category did.
Dish soap to pesticide
A claim that the product sanitizes or disinfects a surface is an antimicrobial pesticide claim, and EPA registers those. A maker who suggests wiping the counter with their dish soap and kills germs in the same breath has crossed into FIFRA.
Inherited marketing is the usual source
A supplier’s description of a surfactant, a competitor’s phrasing copied into a listing, or an old product sheet. Nobody sat down and decided to make a drug claim; it arrived with the copy.
Retailers propagate it
Marketplace listings are frequently written from your own description, so a loose phrase travels to places you do not control. Supplying approved copy is easier than correcting a dozen listings afterwards.
Platforms act before regulators do
Marketplaces and advertising platforms have their own policies on antibacterial and sanitizing claims and they enforce in days. For most small makers the first consequence is a pulled listing, not a letter.
Audit what is already published
Most people reading this have a site and a year of posts written before they thought about any of this. Going through what is live now is the highest-value hour available, and it is the same advice the sun and supplements properties give for the same reason.
Keep a copy of what you approved
When a listing somewhere carries a claim you did not write, the useful response is the approved copy with a date on it. Without that the argument is about who said what, and you will lose it.