The approach here is totally insane.  Basically, since everyone is already trying to violate the FDA, they should modify their definition to fit the products they’re not enforcing… HUH?  What we really need is an easier way to get ‘cosmeceuticals’ into market.  FDA oversight through this process would increase credibility, create standards for efficacy of ‘cosmeceutical’ claims, and take away the snake oil treatments, which there are FAR too many of already.