Topically applied exosome serums are regulated as cosmetics under the FDA's Modernization of Cosmetics Regulation Act (MoCRA), not as drugs, provided you make only permissible cosmetic claims. Facilities must be FDA-registered under MoCRA. No FDA 'approval' exists for cosmetics, but cGMP compliance and facility registration are mandatory. Avoid drug claims like 'regenerates cells' to stay within cosmetic classification.
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