Selected passages from the FDA letter
Quoted FDA text from the published dataset. These selected excerpts are not the complete letter.
Passage 1Your “Naturasil Molluscum Treatment Kit” and “Natural Shingles” 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.
Passage 2Your “Naturasil Molluscum Treatment Kit” and “Natural Shingles” products are not generally recognized as safe and effective (GRASE) for their above referenced uses and, therefore, these products are “new drugs” under section 201(p) of the FD&C Act, 21 U.S.C. 321(p).
Passage 3No FDA-approved application pursuant to section 505 of the FD&C Act, 21 U.S.C. 355, is in effect for these products.
Passage 4Your above-mentioned drugs include non-homeopathic ingredients that, although listed as “inactive ingredients,” are considered active ingredients under 21 C.F.R. 201.66(b)(2) because they are promoted on your website in various places with claims to diagnose, cure, mitigate, treat, or prevent disease, or to affect the structure or any function of the body.
Citations in the original letter
As cited in this historical letter, not a statement of current regulatory requirements.
- 21 CFR 201.66(b)(2)