The claim check, before anything is published

One: does it claim an SPF or sun protection?

If yes, the product is a sunscreen drug product, with testing, a Drug Facts panel and the prohibited words. There is no light version of this answer and it applies to a moisturizer as much as to a sunscreen.

Two: does it claim to repel or control a pest?

If yes, the product is a pesticide and the agency is the EPA, through registration or the minimum risk exemption. Repelling counts even though nothing is killed.

Three: does it claim to treat, heal or prevent anything?

If yes, the product is a drug regardless of what else it is. Naming a condition, describing a symptom or showing a before and after all count, because intended use is read from the whole impression.

Four: if exempt, does it mention disease?

A minimum risk repellent may not claim to control disease-transmitting organisms. This is the single condition most likely to be broken, because it removes exactly the claim the product most wants to make.

Check everything, not just the label

Website, listings, advertisements, stall signage, emails and replies. The label is the part that already gets reviewed; the rest is where these claims actually appear.

Write the answers down

One list of every claim with the category it implies, approved before publication. It is the same register the supplements property describes, and here it has to cover three regimes rather than one.

Run it again whenever anything changes

A reformulation, a new product name, a seasonal campaign or a new marketplace listing each reopen the question. The check is cheap to repeat and the failure it prevents is not.

Decide who is allowed to publish

The common failure is somebody answering a customer helpfully on a Saturday. Agreeing in advance who may write about the product, and what the standard replies are, is part of the control rather than an administrative nicety.

References