Blossom Nature, LLC

This is to advise you that the Food and Drug Administration (FDA) reviewed your website at the Internet address, www.blossom-nature.com, in December 2020. FDA observed that your website directs customers to your Amazon page to purchase your St. John’s Wort product. We have also reviewed your product listing on your Amazon page, http://www.amazon.com/Supplement-National-Antidepressant-Support-Provides-Relief-120/dp/B082TTLJGP, which operates under the name Blossom Nature. The claims on your websites establish that your product is a drug under section 201(g)(1)(B) of the Federal Food, Drug, and Cosmetic Act (the Act) [21 U.S.C. § 321(g)(1)(B)] because it is intended for use in the cure, mitigation, treatment, or prevention of disease. As explained further below, introducing or delivering this product for introduction into interstate commerce violates the Act. You can find the Act and FDA regulations through links on FDA’s home page at www.fda.gov.

Examples of some of the website claims that provide evidence that your St. John’s Wort is intended for use as a drug include:

On the webpage for “St. John’s Wort | Blossom Nature” at www.blossom-nature.com:

"St. John’s Wort is a natural treatment for mental health problems."

"Today, St. John’s Wort is best known as a treatment for depression, anxiety and stress."

"St. John's Wort is effective as prescribed antidepressants but with no side effects."

"St. John’s Wort . . . moderates Seasonal Affective Disorder (SAD)"

"Blossom Nature’s 1 capsule of 450 mg taken twice a day relieves symptoms of depression and anxiety for 24 hours with No Side Effects."

On your Amazon product page at http://www.amazon.com/Supplement-National-Antidepressant-Support-Provides-Relief-120/dp/B082TTLJGP:

On a graphic titled “Blossom Nature’s St. John’s Wort”: "NATURAL ANTIDEPRESSANT HYPERCIN" "GET THE BEST TREATMENT FOR DEPRESSION, ANXIETY AND STRESS with BLOSSOM NATURE’s St. John’s Wort.”

Your St. John’s Wort product is not generally recognized as safe and effective for the above referenced uses and, therefore, this product is a “new drug” under section 201(p) of the Act [21 U.S.C. § 321(p)]. With certain exceptions not applicable here, new drugs may not be legally introduced or delivered for introduction into interstate commerce without prior approval from FDA, as described in sections 301(d) and 505(a) of the Act [21 U.S.C. §§ 331(d), 355(a)]. FDA approves a new drug on the basis of scientific data and information demonstrating that the drug is safe and effective.

A drug is misbranded under section 502(f)(1) of the Act [21 U.S.C. § 352(f)(1)] if the drug fails to bear adequate directions for its intended use(s). “Adequate directions for use” means directions under which a layperson can use a drug safely and for the purposes for which it is intended (21 C.F.R. § 201.5). Prescription drugs, as defined in section 503(b)(1)(A) of the Act [21 U.S.C. § 353(b)(1)(A)], can only be used safely at the direction, and under the supervision, of a licensed practitioner.

Your St. John’s Wort product is intended for treatment of one or more diseases that are not amenable to self-diagnosis or treatment without the supervision of a licensed practitioner. Therefore, it is impossible to write adequate directions for a layperson to use your product safely for its intended purposes. Accordingly, your St. John’s Wort product fails to bear adequate directions for its intended use and, therefore, the product is misbranded under section 502(f)(1) of the Act [21 U.S.C. § 352(f)(1)]. The introduction or delivery for introduction into interstate commerce of this misbranded drug violates section 301(a) of the Act [21 U.S.C. § 331(a)].

The violations cited in this letter are not intended to be an all-inclusive list of violations that exist in connection with your products. You are responsible for investigating and determining the causes of the violations identified above and for preventing their recurrence or the occurrence of other violations. It is your responsibility to ensure that your firm complies with the Act and its implementing regulations.

You should take prompt action to address the violations cited in this letter. Failure to promptly address these violations may result in enforcement action without further notice, including, without limitation, seizure and injunction.

Please notify FDA in writing, within fifteen working days of receipt of this letter, of the specific steps that you have taken to address these violations. Include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation. If you believe that your products are not in violation of the Act, include your reasoning and any supporting information for our consideration. If you cannot complete addressing these violations within fifteen working days, state the reason for the delay and the time within which you will do so. Your reply should be sent via e-mail to FDAAdvisory@fda.hhs.gov.