Two bottles can look similar yet fall into different regulatory categories. In the United States, FDA explains that intended use helps determine whether a product is a cosmetic, a drug, or both.
Appearance and cleansing
A product intended to clean hair or improve its appearance is generally presented as cosmetic care. That is different from a claim to treat a disease or change the body’s structure or function.
Some shampoos are both
FDA uses anti-dandruff shampoo as an example: it cleanses hair, but its treatment purpose can also make it a drug. Claims to restore hair growth can likewise establish a drug intended use. Marketing language on websites matters, not just the wording on the bottle.
For product teams and shoppers
Read what a claim actually promises and do not treat a familiar ingredient name as proof of a medical benefit. This is a general introduction to the U.S. framework, not a complete compliance checklist or legal advice; requirements differ across markets.
Original editorial summary. Source: U.S. Food and Drug Administration: Is It a Cosmetic, a Drug, or Both?. Reviewed October 30, 2026. General information only, not individual medical or legal advice.