QUICK SUMMARY:
The CHC fully supports the FDA's efforts to regulate all products that are labeled homeopathic but that are not in fact homeopathic. The FDA should ensure that only homeopathic products bear the label 'homeopathic'.
Homeopathic drugs are universally recognized as inherently safe and specifically defined as drugs by the Food, Drug and Cosmetic Act (FD&CA). It is our strong view that a separate section of the FD&CA sets out the definition of a "new drug" that explicitly
excludes homeopathy.
The FDA's new guidance moves in a direction we support but has a few gaps that need to be addressed. In particular, we believe the new guidance should specifically differentiate between those products that are in fact homeopathic and those products improperly labeled as homeopathic, allowing the FDA to clearly focus its energies on products falsely labeled as homeopathic.