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Cosmetic or drug

The anticaries monograph

Updated

On this page8
A fluoride toothpaste is an over-the-counter drug, and the monograph decides most of its label.

The actives, by dosage form

A gel or paste dentifrice at 850 to 1,150 ppm theoretical total fluorine: sodium fluoride 0.188 to 0.254 percent with an available fluoride ion concentration at or above 650 ppm. A powdered dentifrice at the same range needs available fluoride at or above 850 ppm with sodium bicarbonate abrasive and a poured-bulk density of 1.0 to 1.2 g/mL.

Which is unusually specific

The monograph names the abrasive and a bulk density for the powder entry. So a tooth powder is not simply a toothpaste without water, and the dosage form carries its own conditions.

Treatment rinses have their own entries

Including acidulated phosphate fluoride solutions at a stated phosphate molarity and pH range yielding a specified effective fluoride ion concentration, and plain sodium fluoride solutions at 0.02 and 0.05 percent at approximately neutral pH.

The identity statement is assembled from menus

Anticavity or fluoride, then one of dentifrice, toothpaste, tooth polish, tooth powder, preventive treatment gel, rinse, concentrated solution, rinse powder or rinse effervescent tablets. Not a phrase you write.

And "mouthwash" is conditionally permitted

The word mouthwash may be substituted for rinse in the identity statement only if the product also has a cosmetic use as defined in the Act. So the familiar word is available only where the product genuinely does both jobs.

The Indication is prescribed too

"Aids in the prevention of dental" followed by one of cavities, decay, caries (decay) or caries (cavities). Other truthful statements describing only the established indication are allowed, narrowly.

A product with no fluoride is a cosmetic

A tooth powder, an oil pulling blend or a whitening gel sold on appearance sits outside the monograph, with cosmetic ingredient labeling instead. That is a simpler label and often the accurate classification.

References

21 CFR 355.10, Anticaries active ingredients, which sets each permitted active by concentration and dosage form: a gel or paste dentifrice at 850 to 1,150 ppm theoretical total fluorine, sodium fluoride 0.188 to 0.254 percent with available fluoride ion at or above 650 ppm, and separate entries for treatment rinses. law.cornell.edu
21 CFR 355.50, Labeling of anticaries drug products. Paragraph (a) assembles the identity statement from fixed menus and allows "mouthwash" in place of "rinse" only where the product also has a cosmetic use; (b) gives the Indication wording; (c)(1) sets the verbatim warning for all fluoride dentifrice products, replacing the general warning statements in 21 CFR 330.1(g). law.cornell.edu
21 CFR 701.3, the cosmetic ingredient declaration, which requires ingredients in descending order of predominance on the label of a cosmetic in package form. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a formulation bench. Whether a product crosses the ethanol or fluoride thresholds is a calculation about your formula and your fill, and whether a pump satisfies the exemption is a question for the pump manufacturer. Nothing here certifies a package.