A product is considered both a cosmetic and a drug when it is intended to affect the structure or function of the body in addition to beautifying — common examples include sunscreens (SPF claims), anti-dandruff shampoos, and fluoride toothpastes. These dual-purpose products must comply with both FDA cosmetic labeling rules and the applicable OTC drug monograph or new drug application, and importers must be prepared to demonstrate compliance at entry.

Fragrances or cosmetics containing ingredients derived from CITES-listed species — such as certain musks, ambergris, or plant extracts from protected species — require CITES import permits and may be subject to US Fish and Wildlife Service review at the port of entry. Importers should audit ingredient sourcing for any animal or plant derivatives before shipment to avoid detention or seizure.