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Product and Regulatory Classification

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A product’s commercial availability does not establish what it is legally authorized to be. Classification must be tied to the exact product, jurisdiction, intended purpose, route of administration, and current evidence.

Status encounteredWhat supports itWhat it does not prove
Approved prescription medicineRegulator-hosted authorization and current product informationApproval in another country or another anatomical area
Nationally authorized medicineNational regulator record within the relevant legal systemOne centralized worldwide approval
CE-marked medical deviceCurrent certificate, intended purpose, legal manufacturer, and applicable EU frameworkMedicinal-product approval or FDA approval
CosmeticProduct labeling and applicable cosmetic registration or notificationAuthorization for injection
Compounded preparationIdentified prescriber/pharmacy framework and exact ingredientsApproval of the compounded preparation as a finished drug
Marketed professional solutionSupplier or manufacturer commercial documentationIndependent authorization, clinical efficacy, or verified sterility
Unapproved drug in a named marketRegulator statement, warning letter, or absence identified through the appropriate approval systemIllegality or status in every other jurisdiction

An accurate approval statement contains at least:

  1. product and presentation
  2. jurisdiction and regulator
  3. indication and anatomical area
  4. date or current record status

For example, the FDA-approved Kybella indication concerns improvement in the appearance of moderate-to-severe convexity or fullness associated with submental fat in adults. Its label states that safe and effective use outside the submental region has not been established and is not recommended (FDA prescribing information 🔗). “FDA-approved fat dissolver” without the product and anatomical limitation is incomplete.

The FDA states that Kybella is the only FDA-approved fat-dissolving injectable drug. It separately names Aqualyx, Lipodissolve, Lipo Lab, and Kabelline as examples marketed online without FDA approval (FDA safety communication 🔗).

This supports precise statements such as not FDA approved in the United States. It should not be expanded into unapproved everywhere.

The European Union does not provide one FDA-style approval statement for every device. If a product is presented as a medical device, verify the current legal manufacturer, intended purpose, device class, notified body, certificate, and whether the evidence belongs to the former Medical Devices Directive or the current Medical Devices Regulation.

EUDAMED is designed to connect actors, devices, certificates, vigilance, and market-surveillance information, but staged implementation and legacy-device rules affect what can be found publicly (European Commission EUDAMED 🔗). A historical CE marked statement alone is insufficient to describe a product’s current status.

Injection and cosmetic identity can conflict

Section titled “Injection and cosmetic identity can conflict”

A product labeled for external cosmetic use should not be interpreted as authorized for injection. Lemon Bottle demonstrates the problem: Swissmedic classified products offered as injectable Lemon Bottle as medicinal products requiring authorization, while the named Korean distributor stated that the authentic cosmetic product was for external use and not injection (Swissmedic warning and addendum 🔗).

For each entry, distinguish where supported:

  • product developer
  • formulation or physical manufacturer
  • legal manufacturer
  • marketing-authorization holder
  • brand owner
  • exporter
  • regional distributor
  • parent company

A distributor listing a product does not automatically establish that it manufactured, developed, or holds authorization for the product.

Use regulator-hosted labels and registration records first. Use current manufacturer documents for declared formulation, presentation, and commercial identity. Treat distributor catalogs as leads when company roles or product status cannot be corroborated. Record evidence gaps rather than filling them with marketplace repetition.