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Can I make a “dandruff control” shampoo as cosmetic-only for the U.S., or does it trigger OTC rules?

Dandruff control claims in US cosmetics require careful formulation to avoid OTC classification; we can help navigate this with proper testing and documentation.

US buyer view Launch planning Updated: January 28, 2026
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Best for
US brand owners, Amazon/FBA sellers, distributors, and private label buyers
Core intent
Who submits, what data is needed, and how to plan timelines before production

Quick Answer (for busy buyers)

Here’s the buyer-first summary. If your brand name is on the label, you usually act as the responsible person and must ensure the listing is submitted and kept current.

  • In the US, dandruff control claims can trigger OTC drug regulations if they imply therapeutic effects.
  • We recommend using cosmetic-only claims like ‘helps reduce visible flakes’ with mild actives like zinc pyrithione at 0.5-1% concentration.
  • Our MOQ starts at 5,000 units for sampling, with 2-3 week turnaround for stability and compatibility testing.
  • We provide full documentation including ingredient safety assessments and claim substantiation support.
  • Packaging must clearly state cosmetic status, and lead time is 8-12 weeks after formula approval.
  • We can help structure your claim language to stay within cosmetic boundaries while delivering effective results.
Buyer outcome
A launch-ready compliance plan: inputs collected, roles assigned, and update cadence defined.
Most common blocker
Missing facility information + inconsistent ingredient/label snapshots across SKUs.
⚠️
This page is a practical buyer guide. For definitive requirements and updates, use FDA resources and qualified regulatory counsel.
  • Our team will answer your inquiries within 8 hours.
  • Your information will be kept strictly confidential.

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