# FDA WARNING_LETTER - Advanced Nutritional Supplements LLC - May 09, 2022

Source: https://www.keypedia.com/records/warning_letter/advanced-nutritional-supplements-llc/d88e88e0-c858-4c0b-9867-8f2008169c28

> FDA WARNING_LETTER for Advanced Nutritional Supplements LLC on May 09, 2022. Product: Food. Access full analysis and detailed observations.

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## Details

- Record Type: WARNING_LETTER
- Company Name: Advanced Nutritional Supplements LLC
- Inspection Date: 2022-05-09
- Product Type: Food
- Office Name: Center for Food Safety and Applied Nutrition
- Summary: This FDA Warning Letter addresses products labeled as dietary supplements: New God of Rage, God of War, New God of Fire, Legion: Extreme Fat Burner, Laxovar: Natural Recomposition, and Uprising: Natural Testosterone Support. The letter states that introducing or delivering these products into interstate commerce violates the Federal Food, Drug, and Cosmetic Act (FD&C Act) because they are adulterated dietary supplements.

The core violation is that the products contain ingredients declared as dietary ingredients (higenamine HCl, hordenine HCl, and 5-alpha-hydroxy-laxogenin) that do not qualify as such under section 201(ff)(1) of the FD&C Act [21 U.S.C. § 321(ff)(1)]. Since these are not dietary ingredients, they are considered non-dietary ingredients. Non-dietary ingredients are subject to food additive regulations and must be generally recognized as safe (GRAS) or approved as a food additive. The FDA states that higenamine HCl, hordenine HCl, and 5-alpha-hydroxy-laxogenin are not GRAS for their intended use in these products.

Therefore, the products are deemed adulterated under section 402(a)(2)(C)(i) of the FD&C Act [21 U.S.C. § 342(a)(2)(C)(i)] because they contain

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