FDA Warning Letter Explorer
Drugs · Feb 11, 2021

Evolved Ayurvedic Discoveries, Inc./BioCBDPlus

3 extracted findings · 1 model-assigned issue type

FDA source excerpt, selected passage

The claims on your website and social media websites establish that your BioCBD+ products are unapproved new drugs sold in violation of sections 505(a) and 301(d) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act), 21 U.S.C. 355(a) and 331(d).

Findings and supporting evidence

Model-assisted readings, not an exhaustive interpretation. Compare with the extracted source findings below.

Labeling, claims & marketing

Products are unapproved new drugs due to disease treatment claims.

Supporting FDA text
Source excerpt · automated text-match check

The claims on your website and social media websites establish that your BioCBD+ products are unapproved new drugs sold in violation of sections 505(a) and 301(d) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act), 21 U.S.C. 355(a) and 331(d).

Labeling, claims & marketing21 CFR 201.5 21 CFR 201.100(c)(2)

Products are misbranded because labeling lacks adequate directions for use.

Supporting FDA text
Source excerpt · automated text-match check

Your BioCBD+ products are also misbranded within the meaning of section 502(f)(1) of the FD&C Act, 21 U.S.C. 352(f)(1), in that their labeling fails to bear adequate directions for use.

Labeling, claims & marketing

Total Body Care is not a dietary supplement because CBD is excluded from the definition.

Supporting FDA text
Source excerpt · automated text-match check

Your “BioCBD+ Total Body Care” product is labeled as a dietary supplement. However, it cannot be a dietary supplement because it does not meet the definition of a dietary supplement under section 201(ff) of the FD&C Act, 21 U.S.C. 321(ff).

Findings extracted from the letter

Selected FDA passages, not the complete letter.

01
The claims on your website and social media websites establish that your BioCBD+ products are unapproved new drugs sold in violation of sections 505(a) and 301(d) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act), 21 U.S.C. 355(a) and 331(d).

Source passage selected by the model

02
Your BioCBD+ products are also misbranded within the meaning of section 502(f)(1) of the FD&C Act, 21 U.S.C. 352(f)(1), in that their labeling fails to bear adequate directions for use.

Source passage selected by the model

03
Your “BioCBD+ Total Body Care” product is labeled as a dietary supplement. However, it cannot be a dietary supplement because it does not meet the definition of a dietary supplement under section 201(ff) of the FD&C Act, 21 U.S.C. 321(ff).

Source passage selected by the model

What FDA requested

Model-assisted summary. Consult the letter for complete requests and conditions.

  • Provide specific steps taken to address the violations
  • Provide explanation of each step being taken to prevent recurrence of violations
  • Provide copies of related documentation
  • If products are believed not in violation, provide reasoning and supporting information

Sections and clauses cited

As cited in this historical letter, not a statement of current regulatory requirements.

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