I’m no attorney, and in case you aren’t one either, here’s a quick link to the FDA’s site with information about cosmetics labeling and when a cosmetic is considered a drug: FDA Cosmetics Labeling Guide
What’s a cosmetic? According to the guide: “A cosmetic is a product, except soap, intended to be applied to the human body for cleansing, beautifying, promoting attractiveness, or altering the appearance.”
When is a cosmetic a drug? According to the guide: “A cosmetic is also a drug when it is intended to cleanse, beautify or promote attractiveness as well as treat or prevent disease or otherwise affect the structure or any function of the human body.”
I’ll save the analysis, but would definitely recommend against using words like “treat” when describing a cosmetic.
Another handy reference.