- The skin plays a minor role in xenobiotic detoxification but responds directly to the systemic burden of oxidative and inflammatory stress. This is the point where ingestible and topicals meet and where the question of which category it belongs in becomes a regulatory choice before becoming a formulation choice.
- Ingestible targets: dermal antioxidant capacity, deposition of carotenoids and tocopherols in stratum corneum, collagen matrix substrate via hydrolyzed collagen peptides with vitamin C as a cofactor for hydroxylation of prolyl and lysyl residues, and dermal microcirculation.
- Topical ingredient targets include: replenishment of barrier lipids, epidermal antioxidant loading, and chelation of catalytic transition metal ions in the formulation base to prevent lipid peroxidation of the skin. Delivery system technology includes liposomes and niosomal carriers, lipid nanoparticles, and cyclodextrins.
- Claim anchor: vitamin C has an authorized EU claim for normal collagen formation, which is important for normal function of skin. Biotin, niacin, and zinc have claims for maintenance of normal skin function. Polyphenols tell the botanical story; the nutrient tells the claim story.
“Cosmeceutical” is a market term, not a regulatory category
- In the United States, a product is either a cosmetic or a drug under the FD&C Act; there is no intermediate class, and the Modernization of Cosmetics Regulation Act (MoCRA) now adds facility registration, product listing, safety-substantiation records and serious adverse event reporting obligations.
- In the EU, Regulation (EC) 1223/2009 requires a Responsible Person, a Cosmetic Product Safety Report and CPNP notification. China regulates under CSAR with NMPA registration or filing depending on function. ASEAN applies to the ASEAN Cosmetic Directive.
- FRL scopes the category question at kick-off, because a claim that is acceptable on an ingestible in one market can convert a topical into a drug in another.