"Our product is a cosmetic — it just has an SPF rating." "Anti-dandruff shampoo is regulated as a drug?" If these questions sound familiar, your facility may already be at risk. You May Be Selling a Drug Without Knowing It The FDA classifies the following products not as cosmetics, but as OTC (over-the-counter) drugs : Sunscreens with SPF claims Acne products containing salicylic acid or benzoyl peroxide Anti-dandruff shampoos containing zinc pyrithione or selenium sulfide To