Handelnine Global, LLC dba Navafresh
7 extracted findings · 4 model-assigned issue types
FDA source excerpt, selected passage
your Navafresh products are drugs under section 201(g)(1) of the FD&C Act, 21 U.S.C. 321(g)(1), because they are 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.
Findings and supporting evidence
Model-assisted readings, not an exhaustive interpretation. Compare with the extracted source findings below.
Products are drugs due to intended use claims for disease treatment or body effects.
Supporting FDA text
Source excerpt · automated text-match checkyour Navafresh products are drugs under section 201(g)(1) of the FD&C Act, 21 U.S.C. 321(g)(1), because they are 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.
Products are unapproved new drugs without FDA-approved applications.
Supporting FDA text
Source excerpt · automated text-match checkNo approved applications pursuant to section 505 of the FD&C Act, 21 U.S.C. 355, are in effect for these products. Accordingly, these products are unapproved new drugs.
Labeling claims to treat serious conditions like cancer, diabetes, and measles.
Supporting FDA text
Source excerpt · automated text-match checkthe labeling of your unapproved “Dr. Patels Measles Tablets,” “Mans-Pachak Vati,” “Adel-54 Heart Care Drops,” “Ayuvardhak Sutta Yog,” “Parkikyor Tablets,” and “Tri-Origin Ayurveda Diabetic Tablets” drug products includes claims to cure, mitigate, treat, or prevent serious and/or life-threatening conditions such as cancer, diabetes, and measles
Rheumacare Capsules misbranded as dangerous due to high lead content.
Supporting FDA text
Source excerpt · automated text-match checkyour “Rheumacare Capsules” product 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 in the dosage or manner recommended in the labeling.
Labeling fails to disclose lead content, making product misbranded.
Supporting FDA text
Source excerpt · automated text-match checkThe labeling for your “Rheumacare Capsules” product does not declare that the product contains lead, which is a material fact with respect to consequences that may result from the use of this product.
Laboratory testing found unsafe lead levels in Rheumacare Capsules.
Supporting FDA text
Source excerpt · automated text-match checkFDA laboratory testing of “Rheumacare Capsules” lot CAM040 and lot CAL079-N found unsafe levels of lead contamination. The individual sample results varied between 9,588ppm and 11,124ppm.
Excessive lead shows manufacturing not conforming to CGMP, adulterating product.
Supporting FDA text
Source excerpt · automated text-match checkAs a result of excessive lead content, your “Rheumacare Capsules” are adulterated under section 501(a)(2)(B) of the FD&C Act, 21 U.S.C. 351(a)(2)(B) because the presence of such substances in the amounts identified by FDA demonstrates that the product has not been manufactured and processed in a manner that conforms to CGMP requirements.
Findings extracted from the letter
Selected FDA passages, not the complete letter.
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What FDA requested
Model-assisted summary. Consult the letter for complete requests and conditions.
- Provide specific steps taken to correct all violations
- Explain each step to prevent recurrence of violations
- Submit copies of related documentation
- Provide reasoning and supporting information if products not in violation
- State reason for delay and time to complete corrections if not within 15 days
Sections and clauses cited
As cited in this historical letter, not a statement of current regulatory requirements.