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Cosmetics were not subject to the 1906 law, but some beauty products like Mme. Yale's Hair Tonic were considered drug preparations. The courts determined that they were misbranded by their claims to cure falling hair and dandruff, remove wrinkles, and feed the skin. The Food, Drug, and Cosmetic Act of 1938 expanded the 1906 law to include all cosmetics.
c. 1910
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