burnd Q&A | Episode 5

What about doctor-branded skin care products?

Most doctor-branded skin care lines are not formulated by the doctors themselves. Instead, they are pre-made formulations produced by contract manufacturers and rebranded under different names and sometimes, doctors will request a custom blend of ingredients, but these products must still comply with regulatory requirements.

Exceptions include if a doctor prescribes a custom formulation for an individual patient, they can legally adjust drug concentrations or use unapproved combinations. This is how compounded medications and prescription-based skin care brands operate.

Can companies put anything they want into a skin care product as long as they don’t make drug claims?

No. The regulatory authorities maintain strict lists of prohibited and restricted ingredients. Companies cannot use certain substances in cosmetics, either because they are classified as drugs or are considered unsafe.

A list of restricted ingredients can be found in the regulatory drug approvals and safety database https://www.accessdata.fda.gov/scripts/cder/daf/index.cfm