Launching a health product without talking to the FDA first invites regulatory trouble later. Submit a pre-submission instead, framing your product as non-medical output rather than a therapeutic claim, so you can get approval to launch without a full device review.
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The main risk which is associated with just launching a solution, either direct-to-consumer or B2B, it doesn't really matter, is the fact that you might get burned out with the FDA if you just launch a solution and then all of a sudden you are knocking on their doors and saying, okay, please clear it now. And the main milestone, baby step to mitigate this risk is a pre-submission in which you notify, ask the FDA for an approval to just launch a non-medical solution. Again, in our case, It's basically a definition or an output definition, rather than saying, okay, we see an effective treatment, we can actually state, okay, we see an overall compounded physiological change as a proxy for efficacy decision support.