1. Many products (suggested by Veterinarians) are legal without FDA approval. Such products include animal supplements, medical feed, and compounded drugs.
2. If a product does not require FDA approval, like a hemp CBD animal supplement, then no FDA approval is needed for the product to be legal. The reason you (Veterinarians) can use, recommend, and sell such products is that the FDA does not regulate animal supplements as drugs.
3. The Food, Drug and Cosmetic Act has a broad definition of what an animal drug is. While the definition says that products intended to treat a disease or affect the structure of an animal’s body are considered a drug, the definition is not literal. If the definition were literal, then you (Veterinarians) could not use, recommend, or sell animal supplements like Denamarin, fish oil, or glucosamine.
4. The FDA long ago concluded that the federal Dietary Supplement Health and Education Act does not apply to products marketed as dietary supplements for animals, stating, “There is no ‘dietary supplement’ regulatory classification for animal food substances and products” and, “They are considered either ‘foods’ or ‘new animal drugs’ depending on the intended use.”
5. The hemp CBD manufacturers that received FDA warning letters for selling unapproved animal drugs, explicitly claimed that their products treated or cured cancer and other diseases. While those particular products from the manufacturers are drugs, hemp CBD animal products that manufacturers do not intend to be used to treat a disease are not drugs. Telling Veterinarians that hemp CBD products are illegal unless they are FDA approved, harms animals and veterinary businesses.
コメント