Having an NDC code isn’t necessary for something to be considered a drug. The question is whether it’s used and applied in the same manner as a medication or behaves more like a device. I would say drug supplements and even hand sanitizer fit in the same space as medications - they are consumed in their use, and they are ingested or topically applied with the intention of changing the physiologic state of the subject. Wipes probably fit more in the space of a device, specifically a single-use device.