Seizure of Cosmetic Signals New Enforcement Trend

The article highlights the FDA’s November 2007 seizure of Jan Marini’s “Age Intervention Eyelash” product as one in a series of recent FDA enforcement actions against cosmetic and dietary supplement companies that appear to classify products as unlawfully marketed “drugs” based on their use of ingredients that are also used in prescription drugs. This trend marks a tactical change from the FDA that industry should watch closely.

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