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Is this for you at all

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Two of the three products here are reachable for a small maker. Sunscreen generally is not, and it is worth knowing that before the first batch.

Why sunscreen is the hard one

The SPF on the label comes from testing on human subjects to a prescribed method, and so does the broad spectrum designation. That is a laboratory service with a real cost and a lead time, and it has to be repeated when the formulation changes. It is the single biggest barrier on this shelf.

And the formulation is not forgiving

Active ingredients, their concentrations and the finished product’s performance are tightly connected, so adjusting a sunscreen for feel or cost can move the SPF. You cannot tune it the way you would a lotion and then declare the old number.

Repellent is a middle case

A registered product is a serious regulatory undertaking. A minimum risk product using exempt ingredients is genuinely accessible, with real constraints on what it may claim, and that is the route most small makers take.

The cosmetic end is straightforward

Aloe gels, after sun lotions and tanning oils are cosmetics, and the requirements are those of any cosmetic. For somebody who wants to be on this shelf without entering a drug or pesticide regime, that is the door.

Read the claim rules before formulating

Because the things you naturally want to say about a product for sun exposure are frequently the things that move it into another category. That is the whole difficulty and it is a writing problem more than a chemistry one.

What this property covers

Which regime each product is in, the specific rules that catch people, and the container decisions. It does not formulate and it does not clear a label.

Private label is a real route to the hard end

Selling somebody else’s tested sunscreen or registered repellent under your own brand gets you onto this shelf without the testing, and it makes you responsible for the label. That trade is worth understanding before dismissing the category as closed.

References

21 CFR 201.327, Over-the-counter sunscreen drug products; required labeling based on effectiveness testing. Paragraph (g) makes “sunblock”, “sweatproof” and “waterproof” false or misleading; paragraph (a)(2) permits only “Water Resistant (40 minutes)” or “(80 minutes)”; paragraph (d)(2) carries the Skin Cancer/Skin Aging Alert. law.cornell.edu
40 CFR 152.25, Exemptions for pesticides of a character not requiring FIFRA regulation, including the minimum risk exemption: active ingredients named with their percentage by weight, inert ingredients by their designated names, company name and contact information, and no claim to control disease-transmitting organisms. law.cornell.edu
Written from federal regulation, not from a formulation lab. A sunscreen is an OTC drug and an insect repellent is a pesticide, and both carry requirements that a cosmetic does not. Nothing here clears a specific label, and the difference between a cosmetic claim and a drug claim is narrower than it looks.