Presumably the item in question is not an ointment or cream, but some sort of device. Personally I'm having trouble imagining what sort of 'cosmetic device' suddenly now has a medical purpose. I jumped to decorative contact lenses only because I'm aware of some past FDA crackdowns in that area. Maybe a foot spa? There are likely bigger issues with the new marketing plan than trying to comply with 14971, but a rigorous application the standard would be a benefit to the manufacturer, even if they only see having a RMP as some sort of paperwork exercise.