Is retinol in a body scrub regulated by the FDA?

When marketed with cosmetic claims only (e.g., smoother skin, improved texture), a retinol body scrub is regulated as a cosmetic under FDA MoCRA, which now requires facility registration and product listing. Drug claims trigger stricter OTC or NDA requirements. Your cosmetic chemist and AJ Cosmo Labs manufacturers can advise on compliant claim language before you finalise your label.