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Wednesday, September 28, 2011 12:31:17 PM
"In addition, only products that are intended for ingestion may be lawfully marketed as dietary supplements. You promote “Eyebright Formula” to “heal eye infections and other eye disturbances” with intended topical uses for conjunctivitis. “Candida-G” is also promoted for cervix infections to be used as a vaginal implant. For these intended uses, “Eyebright Formula” and “Candida-G” are not a dietary supplement because they are not intended for ingestion. 21 U.S.C. 321(ff)(2)(A)(I) defines the term, “dietary supplement” to mean a product that is intended for ingestion. Consequently, a product that is not intended for ingestion cannot be a “dietary supplement.”
Maybe it could be marketed as a dietary supplement until clinical trials and therefore meet FDA requirements. It is ingested since it is water.
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