As mentioned by Dr. Placik, obtaining FDA approval for a filler is indication and location specific. Since the original fillers were bovine collagen (zyderm and zyplast), most studies with new fillers performed are designed to compare themselves to collagen. The original studies on collagen were performed in the nasolabial fold region. Use of fillers in the infraorbital area is a relatively recent development. The process of obtaining FDA approval for this area would be arduous and expensive and may not confer any competitive advantage to the company that proceeds.
Why Aren't Cosmetic Fillers FDA Approved for the Under Eye Area?
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FDA approval of fillers
When filler manufacturers apply for FDA approval they have to prove the products are safe and that they work. In order to prove they work there has to be a grading scale of severity before and after injection. For fillers this is easier to do in the nasolabial folds than other areas.
For botox this easiest for the frown lines between the eyebrows. Regulations being what they are when the material is approved it is only approved for that specific area of the body and when used in other areas it is considered off label use. If they tried to get the fillers approved for all possible areas of the body it would be very expensive to do so and it may be difficult or impossible to grade severity in a photo of some body areas.
Facial filler FDA approval process and new indications.
Fillers are approved according to FDA approved studies. Generally this requires comparing a new filler to older established fillers using them as a gold standard. Trying to get a study approved for a whole new indication can be extremely costly and most companies avoid this. For the face, the vast majority of fillers are evaluated using the nasolabial fold because this was established as the standard when collagen was first approved. Typically most fillers today are compared to Restylane which also was initially approved for filling the nasolabial fold. Once approval is achieved for a specific area, it can be used "off-label" for filling nearly any other area.
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