Products containing glycolic acid or lactic acid as alpha-hdyroxy acids (AHAs) do not need to be registered with the FDA (but products contains salicylic acid which is considered a OTC drug). However, the FDA adopted guidelines in terms of using these AHAs. Based on the Cosmetic Ingredient Review (CIR) Expert Panel — the industry's self-regulatory body for reviewing the safety of cosmetic ingredients — products containing the AHAs glycolic and lactic acid are safe for use by consumers if:
  • The AHA concentration is 10% or less.
  • The final product has a pH of 3.5 or greater.
  • The final product is formulated in such a way that it protects the skin from increased sun sensitivity or its package directions tell consumers to use daily protection from the sun.
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