FDA Warning Letter Explorer
Drugs · Apr 13, 2022

Genomma Lab USA, Inc.

1 extracted findings · 2 model-assigned issue types

FDA source excerpt, selected passage

Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are drugs as defined by section 201(g)(1)(B) of the FD&C Act, 21 U.S.C. 321(g)(1)(B), because they are intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease and/or under…

Findings and supporting evidence

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

Labeling, claims & marketing

Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are drugs as defined by section 201(g)(1)(B) of th

Supporting FDA text
Source excerpt · automated text-match check

Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are drugs as defined by section 201(g)(1)(B) of the FD&C Act, 21 U.S.C. 321(g)(1)(B), because they are intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease and/or under section 201(g)(1)(C) of the FD&C Act, 21 U.S.C. 321(g)(1)(C), because they are intended to affect the structure or any function of the body. Specifically, these products are intended for use as skin bleaching products.

Labeling, claims & marketing21 CFR part 330

Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are skin bleaching drugs subject to section 505G o

Supporting FDA text
Source excerpt · automated text-match check

Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are skin bleaching drugs subject to section 505G of the FD&C Act, 21 U.S.C. 355h, which governs nonprescription drugs marketed without an approved application. Specifically, these skin bleaching products fall under section 505G(a)(4) of the FD&C Act, 21 U.S.C. 355h(a)(4), as added on March 27, 2020 with the enactment of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), because they are subject to a determination to be not generally recognized as safe and effective (GRASE) in a proposed rule that is the most recently applicable proposal issued under 21 CFR part 330.

Registration, listing & premarket

No FDA-approved application pursuant to section 505 of the FD&C Act, 21 U.S.C. 355, is in effect for Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and t

Supporting FDA text
Source excerpt · automated text-match check

No FDA-approved application pursuant to section 505 of the FD&C Act, 21 U.S.C. 355, is in effect for Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM. Accordingly, these skin bleaching drug products are unapproved new drugs and their introduction or delivery for introduction into interstate commerce violates section 505(a) of the FD&C Act, 21 U.S.C. 355(a).

Labeling, claims & marketing

Moreover, Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are misbranded under section 502(ee) of

Supporting FDA text
Source excerpt · automated text-match check

Moreover, Cicatricure® MEDICAL LIGHTENING SKIN LIGHTENING CREAM and teatrical® PRO-ACLARANT SKIN LIGHTENING NIGHT CREAM are misbranded under section 502(ee) of the FD&C Act, 21 U.S.C. 352(ee), because they are deemed as such under section 505G(a)(4) of the FD&C Act, 21 U.S.C. 355h(a)(4), and because they are nonprescription drugs subject to section 505G of the FD&C Act, 21 U.S.C. 355h, but are not the subject of applications approved under section 505 of the FD&C Act, 21 U.S.C. 355, and do not comply with the requirements under section 505G of the FD&C Act, 21 U.S.C. 355h.

Findings extracted from the letter

Selected FDA passages, not the complete letter.

01
Failure to address violations of the FD&C Act may be cause for FDA to withhold approval of requests for export certificates and approval of pending new drug applications or supplements listing your facility as a supplier or manufacturer.

What FDA requested

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

  • Respond in writing within 15 working days specifying what you have done to address any violations and to prevent their recurrence.
  • If you cannot completely address violations within 15 working days, state your reasons for delay and schedule for completion.
  • If you believe that your products are not in violation of the FD&C Act, include your reasoning and any supporting information for our consideration.

Sections and clauses cited

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

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