Warning letter · FDA Warning Letters, Historical Archive

Earth Turns, LLC: FDA Warning Letter 566232 (Feb 5, 2019)

Agency action: Feb 5, 2019Record ID: fda_warning_-752bfba3e0ee099b
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What happened

Original notice title

Earth Turns, LLC MARCS-CMS 566232, February 05, 2019

From the archived source record

On the webpage titled, “Pure Encapsulations – Green Tea Extract (Decaffeinated)”: “Green tea extract may also help to regulate blood sugar and reduce the risk of type 1 diabetes.” On the webpage titled, “How Can I Improve My Memory?” for an ingredient found in your Cogni-Flex product: “Huperzine A is another supplement, known as Chinese club moss. A drug is misbranded under section 502(f)(1) of the Act [21 U.S.C. § 352(f)(1)] if the drug fails to bear adequate directions for its intended use(s). Accordingly, Green Tea Extract, Cogni-Flex, GlucoFit 48mg, Fundamental D3 1000, and Fundamental Omega-3 fail to bear adequate directions for their intended use and, therefore, the products are misbranded under section 502(f)(1) of the Act [21 U.S.C. § 352(f)(1)]. The introduction or delivery for introduction into interstate commerce of these misbranded drugs violates section 301(a) of the Act [21 U.S.C. § 331(a)]. The violations cited in this letter are not intended to be an all-inclusive statement of violations that exist in connection with your products. You are responsible for investigating and determining the causes of the violations identified above and for preventing their recurrence or the occurrence of other violations. You should take prompt action to correct the violations cited in this letter. Failure to promptly correct these violations may result in legal action without further notice, including, without limitation, seizure and/or injunction. Within fifteen working days of receipt of this letter, please notify this office in writing of the specific steps that you have taken to correct violations. Include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation. If you believe that your products are not in violation of the Act, include your reasoning and any supporting information for our consideration.

What the official notice says to do

Check the original notice for the instructions that apply to the named product, company, and affected lots.

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Status and source details

Status recorded in the archive
Historical warning letter; closeout not established by annual index
Source checked
Jul 16, 2026
Record revision
d4e4bc62f947

This is a dated record. Its current status may have changed since the source was captured. A record applies to its stated scope; it is not a safety rating for every product from a company.

Sources, dates, and coverage →

What is affected

Product
Natural Diabetes Supplement; Fundamental D3 1000; Pure Encapsulations Green Tea Extract (decaffeinated) - Made in USA - 120 Capsules; Green Tea Extract; Cogni-Flex; GlucoFit 48mg; and Fundamental Omega-3
Company
Earth Turns, LLC
Lot / identifier
The source does not specify this field.
Market / distribution
The source does not specify this field.