Virginia (202) 466-6937 | Arizona (602) 388-8899

How FDA and EFSA Prior Restraints Defeat Government Objectives and Foster Fraud and Deception

By Jonathan W. Emord FDA and EFSA censorship regimes are based on an anti-fraud or anti-deception rationale.  In short, FDA presumes that deprivation of all information not officially sanctioned that expressly or impliedly links a nutrient with a disease helps prevent consumers from being misled.  Likewise, EFSA presumes that deprivation of all information not officially […]

Drug Industry Acquisition of the Supplement Marketplace

Although market leaders in the supplement industry appear to be coping with the present recession, most are experiencing a downturn in sales and a few are doing better than in prior years.  The bulk of small to mid-sized companies are struggling, caught in a squeeze between a dramatic reduction in demand and a dramatic increase […]

EU Maximum Vitamin and Mineral Dose Levels

In an excellent piece by Shane Starling in today’s Nutraingredients.com, Shane explains the debate now raging in the UK over the 2002 EU Food Supplements Directive provision requiring the setting of maximum permitted levels for nutrients in food supplements.  He explains that an estimated 700 health food stores and 4000 jobs would be lost throughout […]

The Uncoupling of Injury from Adulteration

The pyridoxamine example, well explained by Bethany in her blog post, proves the inherent pitfalls in 21 USC 321(ff)(3)(A)-(B).  As we have seen, the new interpretation given by FDA to the term “New Dietary Ingredient,” the FDA’s redefinition of adulteration standards through its Good Manufacturing Practice Guidelines, and the changes effected by the Food Safety […]

FDA’s Evisceration of the Labeling Exemption in 21 USC 343-2

The FDA has rendered the labeling exemption in 21 USC 343-2 a dead letter through construction.  That provision of the Dietary Supplement Health and Education Act was inartfully written but nevertheless designed by Congress to liberate dietary supplement companies from the prohibition on nutrient-disease claims in 21 USC 343 when they supplied independent scientific literature […]


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Virginia (Firm HQ)

11808 Wolf Run Lane
Clifton, VA 20124
Telephone: (202) 466-6937
Telecopier: (202) 466-6938

Arizona

2730 S. Val. Vista Dr.
Bldg. 6, Ste 133
Gilbert, AZ 85295
Telephone: (602) 388-8899
Telecopier: (602) 393-4361