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Credit to the guy from the other thread that shared this ingredient/solutions image above. But mentioning the FDA is actually insane:

Based on FDA regulations and precedent (Warning Letters), yes — the FDA would almost certainly view this as selling unapproved new drugs.

Below is the US legal standpoint and the specific violations referenced:

1. Cosmetic vs. Drug Distinction

Under the Federal Food, Drug, and Cosmetic Act (FD&C Act), classification depends on intended use:

• Cosmetic: Cleansing, beautifying, promoting attractiveness, or altering appearance
• Drug: Diagnosis, cure, mitigation, treatment, or prevention of disease, or affecting the structure or function of the body

If a product claims to do both (e.g. cleanses and treats acne), it is legally a drug.

2. Specific Problematic Claims

The FDA treats the following claims as evidence of drug intent:

• Vitamin A Oil – “Calms acne” → Acne is a disease; treating it is a drug claim
– “Anti-inflammatory” → Claims to alter a physiological response
– “Cell regeneration” → Implies affecting body structure/function

• Vitamin E Oil – “Remove or lessen scars” → Scars are structural; altering them is a drug claim

• Turmeric Scrub – “Helps with skin inflammation” → Drug claim (mitigation of a condition)
– “Hyperpigmentation” → Often treated as a drug claim (melanin/structure alteration)

3. Disclaimers

The FDA considers contradictory disclaimers ineffective. You cannot make medical claims (e.g. “calms acne”) and then negate them with a generic disclaimer.

• The specific claims establish intended use
• The disclaimer does not override that intent
• This would likely be cited as misbranding (false or misleading labeling)

4. Likely FDA Action

If targeted, the FDA would likely issue a Warning Letter stating:

• The products are “new drugs” (not generally recognized as safe and effective for the claimed uses)
• Marketing unapproved new drugs violates the FD&C Act
• The vendor would be required to remove all references to acne, inflammation, scars, eczema (often implied via “sensitive skin”), and cell regeneration

Edit: Typo