https://ec.europa.eu/growth/sectors/cosmetics/cosing_en
"If, due to such ingredients, a product restores, corrects, or modifies physiological functions by exerting a pharmacological, immunological or metabolic action, the product shall be qualified as a medicinal product. However, products that, while having an effect on the human body, do not significantly affect the metabolism and thus do not strictly modify the way in which it functions, may be qualified as cosmetic products."
The qualification of a product is to be decided by the national competent authorities, under the supervision of the courts, on a case-by-case basis, taking into account all the characteristics of the product.
In addition, the use of any ingredient in cosmetic products must be supported by a safety assessment of the product."
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I think the lotion autoqualifies as a drug even in Europe. They are doing/have done the necessary safety tests and most likely are trying to seek approval for it to be a cosmetic. This process may take time since they're done on a case-by-case basis. And it honestly might get denied cosmeticship since the lotion does have a relatively strong physiological effect on the body, even if it's deemed super safe. If it doesnt get approved as a cosmetic in Europeyou can kiss it goodbye.
And just as a throwback to old discussions, the claim to restore 5 years of loss is a nonsensical claim, so please don't give it any weight. If you go from 100 terminal hairs per square cm to 25 in a year, you're not getting that sh*t back from this lotion, no matter how good it is.