Homeopathic Pharmacopoeia of the United States.<\/a> Homeopathic medicines are therefore recognized in federal law.<\/p>\n<\/p>\n
2. The FDA asserts in its Guidance (which is not a law!) that because homeopathic medicines are \u201cunapproved new drugs,\u201d they are subject to premarket approval requirements. The Agency states that there are no FDA approved homeopathic medicines and that this is why FDA is going to treat homeopathic medicines as if they are being \u201cillegally marketed.\u201d (Again, this is just the FDA\u2019s thinking and we do NOT agree with it.) The FDA therefore claims that it can remove any homeopathic medicine from the market at any time without any reason other than that it is being marketed illegally.<\/p>\n
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This is having a \u201cchilling\u201d effect on the market for homeopathic medicines. We are very concerned about that. This Guidance explains how the FDA will remove homeopathic medicines from the market. But it provides absolutely no path for homeopathic medicines to enter and remain in the market legally.<\/p>\n
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The FDA has stated that homeopathic medicines can go through the drug approval
process. But that process was designed for chemical pharmaceuticals to determine
whether their risks (usually toxic risks) are outweighed by their benefits. In addition, the
cost of such applications runs in the tens of millions of dollars. Since homeopathic
medicines are NOT patentable\u2014they are made from commonly available
substances\u2014there is no way for any company making such an application to recoup its
investment in the application.<\/p>\n
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The FDA knows this because we met with Agency personnel and explained it to them.
The FDA admitted that the new drug application process doesn\u2019t work for homeopathic
medicines. The Agency stated that it is using the designation of \u201cunapproved new drug\u201d
as an enforcement tool to give it the authority to remove homeopathic medicines
whenever necessary.<\/p>\n
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The Guidance states that many homeopathic medicines fall outside the enforcement
priorities of the Agency. But because the Guidance is not law, the Guidance may be
disregarded by the Agency whenever it wishes to. It is true that the FDA would have to pull medicines off the market one-by-one and would likely end up in court as a result. It could not, for instance, pull all versions of Aconitum napellus off the market all at once.<\/p>\n
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But the FDA has other means to force medicines off the market, namely, conduct a
smear campaign using unfounded accusations to frighten consumers away and thus force companies to discontinue manufacture of the targeted medicines. Another way is blocking imports of homeopathic medicines – which is already happening.<\/p>\n
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Americans for Homeopathy Choice formed to fight this deeply flawed Guidance and we need your help now more than ever. Please consider signing up for the Homeopathy Action Team. This is a critical group for connecting us to Congress where we think we have a chance to pass legislation that will protect homeopathy.<\/p>\n
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We are a resource for members of Congress and their staffs. It\u2019s important that WE are seen as the source of reliable information, NOT the FDA, NOT Wikipedia. One of our HAT members actually received a call from a Congressional staff person almost as soon as the Guidance was finalized. The staff person was concerned about this development and asking for updates.<\/p>\n
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This is why joining the Homeopathy Action Team is so important. The deadline to enroll is Tuesday, December 13. After the initial training, there is only a modest time
commitment each month.<\/p>\n
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There are two other things you can do: 1) Become a free member and sign up to receive our weekly Insider report and occasional alerts and 2) make a donation<\/a>. We need financial resources to wage this fight.<\/p>\n<\/p>\n
Thank you so much. I\u2019ll see you after the New Year with another Homeopathy Choice Insider report.<\/p>\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t