Warning letter · FDA Warning Letters, Historical Archive

MA Labs LLC: FDA Warning Letter 566831 (Nov 7, 2018)

Agency action: Nov 7, 2018Record ID: fda_warning_-f22f579566bfe364
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What happened

Original notice title

MA Labs LLC MARCS-CMS 566831, November 07, 2018

From the archived source record

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, your Vicaine product fails to bear adequate directions for its intended use and, therefore, the product is 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 this misbranded drug violates section 301(a) of the Act [21 U.S.C. § 331(a)]. Adulterated Dietary Supplements Even if your Vicaine product did not have claims that make it an unapproved new drug and misbranded drug, Vicaine would be an adulterated dietary supplement under section 402(a)(2)(C)(i) of the Act [21 U.S.C. § 342(a)(2)(C)(i)] because it contains an unsafe food additive. Any food additive that has not been approved for its intended use in food is deemed to be unsafe and causes the food to be adulterated under section 402(a)(2)(C)(i) of the Act [21 U.S.C. § 342(a)(2)(C)(i)] . Adulterated foods cannot be legally imported or marketed in the United States. Because tianeptine does not qualify as a dietary ingredient and is not GRAS or otherwise exempt from the food additive definition, your Vicaine product is adulterated under section 402(a)(2)(C)(i) of the Act [21 U.S.C. § 342(a)(2)(C)(i)] because it contains an unsafe food additive. 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.

What the official notice says to do

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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
1b381940b5aa

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.

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What is affected

Product
Unapproved New Drugs/Misbranded
Company
MA Labs LLC
Lot / identifier
The source does not specify this field.
Market / distribution
The source does not specify this field.