Guidance on OTC Sunscreen Product Enforcement Policy

FDA has published a guidance on “Enforcement Policy — OTC Sunscreen Drug Products Marketed Without an Approved Application” that describes the agency’s enforcement approach with respect to such during the period before a final sunscreen monograph becomes effective. The document notes that OTC sunscreens marketed without approved applications and containing certain active ingredients are subject to labeling and testing requirements. It says that until a final OTC monograph for sunscreen products is in place, the agency will continue to exercise enforcement discretion for certain OTC sunscreen products marketed without approved NDAs.

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