However, the categorization again is fuzzy, with definitional overlap between "planet", "sub-brown-dwarf", and "brown dwarfs"
Planets cover spherical objects ranging from 0.001 Jupiter masses to stars at ~80 Jupiter masses. Brown dwarfs range from 3-80 Jupiter masses.
Brown Dwarfs are planets and can form outside of an accretion disk. Planets smaller than brown dwarfs are not thought to be able to form outside of accretion disks.