Uh...I'd say the attorneys at the FEDERAL GOVERNMENT FDA WOULD BEG TO DIFFER....as they review and likely write the text of any and all formal "WARNING LETTERS" sent out-
This is the WARNING LETTER and ACCOMPANYING FORMAL FDA "PR" issued to USSC and Kristin Comella and it cites NUMEROUS LAWS BEING BROKEN, all codified, all detailed to the minutia.
I trust FDA ATTORNEYS and possibly U.S. ATTORNEYS more than some "comment" or a Youtube video by a non M.D., non attorney, or a "blog" etc.