Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1FDA confirmed through laboratory analysis that a sample of your product, “SANGTER Energy Supplement,” contains the undeclared active pharmaceutical ingredient (API), sildenafil, which is a phosphodiesterase type-5 (PDE-5) inhibitor.
Passage 2“SANGTER Energy Supplement” is a drug as defined by section 201(g)(1) of the FD&C Act, 21 U.S.C. 321(g)(1) because it is intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease and/or intended to affect the structure or any function of the body.
Passage 3“SANGTER Energy Supplement” is not generally recognized as safe and effective for its above referenced uses and, therefore, is a “new drug” under section 201(p) of the FD&C Act, 21 U.S.C. 321(p).
Passage 4“SANGTER Energy Supplement” is also misbranded under section 502(f)(1) of the FD&C Act, 21 U.S.C. 352(f)(1), in that the labeling fails to bear adequate directions for its intended use(s).
Passage 5Additionally, “SANGTER Energy Supplement” is misbranded under section 502(a) of the FD&C Act, 21 U.S.C. 352(a).
Passage 6The undeclared sildenafil in “SANGTER Energy Supplement” also causes the product to be misbranded under section 502(f)(2) of the FD&C Act, 21 U.S.C. 352(f)(2), because the labeling lacks adequate warning for the protection of users.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.5
- 21 CFR 201.100(c)(2)