321(g)(1), because they are intended for use in the diagnosis, cure, mitigation, treatment, or prevention of disease and/or because they are intended to affect the structure or any function of the body. Unapproved New and Misbranded Human Drug Productsīased on our review of your websites, your “CBD Salve” and “CBD Oil” products are drugs under section 201(g)(1) of the FD&C Act, 21 U.S.C. 351(a)(5). As explained further below, introducing or delivering these products for introduction into interstate commerce for such uses violates the FD&C Act. You can find the FD&C Act and FDA regulations through links on FDA’s home page at In addition, the Federal Trade Commission (FTC) has reviewed your website for potential violations of Sections 5(a) and 12 of the FTC Act, 15 U.S.C. 360b(a), and adulterated under section 501(a)(5) of the FD&C Act, 21 U.S.C.
FDA has also determined that your “CBD for Dogs” product is an unapproved new animal drug that is unsafe under section 512(a) of the FD&C Act, 21 U.S.C. Furthermore, these products are misbranded drugs under section 502(f)(1) of the FD&C Act, 21 U.S.C.
FDA has determined that your “CBD Salve” and “CBD Oil” 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).
We have also reviewed your website at the internet address and your social media websites at and these websites direct consumers to your website, to purchase your products. Food and Drug Administration (FDA) reviewed your website at the internet address in February 2019 and has determined that you take orders there for the products “CBD Salve,” “CBD Oil” (in 5 different flavors), and “CBD for Dogs,” which you promote as products containing cannabidiol (CBD). Advanced Spine and Pain, LLC (d/b/a Relievus)
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