Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1the active ingredient, ethanol, was substituted wholly or in part with methanol
Passage 2in that the substitution demonstrates that the quality assurance within your facility is not functioning in accordance with Current Good Manufacturing Practice (CGMP) requirements
Passage 3this product is an unapproved new drug marketed in violation of sections 505(a) and 301(d) of the FD&C Act
Passage 4It is misbranded under section 502(j) of the FD&C Act, 21 U.S.C. 352(j), because it is dangerous to health when used according to its labeling as a hand sanitizer
Passage 5The failure of this drug product to list methyl alcohol (methanol) as an ingredient on its label causes it to be misbranded under section 502(e)(1)(A)
Passage 6this product is misbranded under section 502(ee) of the FD&C Act, 21 U.S.C. 352(ee) because NEXT ADVANCED ANTIBACTERIAL HAND SANITIZER is a nonprescription drug subject to section 505G of the FD&C Act, 21 U.S.C. 355h, but does not comply with the requirements for marketing under that section
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.128
- 21 CFR 330.1(e)
- 21 CFR 330