I'm not sure, but I would not be surprised if they had to go through approval again for other applications since the base formulation would most likely change. Unless a normal base is used (Hydrocortisone, etc). My guess is they would be using a different base vehicle formulation for a face (acne), as opposed to arms. Since most people with acne have finicky skin prone to breakouts, they would not want to use a heavy cream like with arms and legs.
It's a possibility... FWIW