IMO I think the detail of the wording will be the way forward, regarding wether or not it qualifies under the cosmetic/ personal care category.
They are using the term “Nasal Sanitising Balm” which IMO at this point in time looks to qualify under those above categories.And possibly any associated claims on the package and how they are worded etc will also play a part.
They have obviously looked into this already to clear any roadblocks, but anything is still possible.
Taken from the Q and A earlier.
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