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.
Classification map
Section titled “Classification map”| Status encountered | What supports it | What it does not prove |
|---|---|---|
| Approved prescription medicine | Regulator-hosted authorization and current product information | Approval in another country or another anatomical area |
| Nationally authorized medicine | National regulator record within the relevant legal system | One centralized worldwide approval |
| CE-marked medical device | Current certificate, intended purpose, legal manufacturer, and applicable EU framework | Medicinal-product approval or FDA approval |
| Cosmetic | Product labeling and applicable cosmetic registration or notification | Authorization for injection |
| Compounded preparation | Identified prescriber/pharmacy framework and exact ingredients | Approval of the compounded preparation as a finished drug |
| Marketed professional solution | Supplier or manufacturer commercial documentation | Independent authorization, clinical efficacy, or verified sterility |
| Unapproved drug in a named market | Regulator statement, warning letter, or absence identified through the appropriate approval system | Illegality or status in every other jurisdiction |
Approval needs four coordinates
Section titled “Approval needs four coordinates”An accurate approval statement contains at least:
- product and presentation
- jurisdiction and regulator
- indication and anatomical area
- 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.
FDA approval is a US fact
Section titled “FDA approval is a US fact”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.
European claims require current documents
Section titled “European claims require current documents”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 🔗).
Use narrow company roles
Section titled “Use narrow company roles”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.
Documentation hierarchy
Section titled “Documentation hierarchy”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.

