Ionic Silver Water, L-Glutathione, Liposomal DHA – Ultimate Omega-3 Brain Support, Liposomal Methyl B12/Folate, NAC N-Acetyl-L-Cysteine, and Vectomega. FDA also reviewed your social media website at www.facebook.com/Mars.Venus.John.Gray, which provides a link to your website at www.marsvenus.com. T
he claims on your websites establish that these products are drugs under section 201(g)(1)(B) of the Federal Food, Drug, and Cosmetic Act (the Act) [21 U.S.C. § 321(g)(1)(B)] because they are intended for use in the cure, mitigation, treatment, or prevention of disease. As explained further below, introducing or delivering these products for introduction into interstate commerce for such uses violates the Act. You can find the Act and FDA regulations through links on FDA’s home page at
- “Glutathione … is the secret to preventing … heart disease, dementia and necessary to treat everything from ADHD, to autism to Alzheimer’s disease.”
- “These following steps are crucial to preventing Alzheimer’s disease and so effective, they could reverse the momentum of Alzheimer’s.
- “If you are taking a statin drug just because your cholesterol levels are high and you have no history of heart disease, reconsider taking it. There are much better ways to avoid a heart attack, including fish oil…”
- Below this claim, there is a link that says, “CLICK HERE to learn more about the products discussed in this video.” This link goes to the website https://www.marsvenus.com/list/search/f%7E[high-cholesterol, which list several products, including Vectomega. The Vectomega product page states that “Vectomega contains up 50 times higher triglyceride fish oil than other omega oil supplements.”
- “Ionic Silver Water helps you fight off a cold or flu…”
- “Silver is the ultimate antidote to germs. Silver is often used in medicine to prevent infections, including with wound dressings, urinary catheters and breathing tubes.”
- “‘Fights viral infections”
- “NAC helps… protect the body from the damaging effects of chemotherapy, cigarette smoke…”
- For your 2-AEP Membrane Complex product: “asthma, migraine. . . . anxiety”
- For your Ionic Silver Water: “silver antibiotics”
- For your L-Glutathione : “heart disease, . . . necessary to treat everything from ADHD, to autism to Alzheimer’s disease. . . . cancer, alzheimers disease, autism, adhd, cancers, . . . mercury poisoning”
- For your Liposomal DHA – Ultimate Omega-3 Brain Support: “parkinsons disease, alzheimers disease, alzheimers, . . . brain injury”
- For your NAC N-Acetyl-L-Cysteine: “parkinsons disease, . . . alzheimers, cancer”
- On May 28, 2018, and January 8, 2018, you posted the following: “Omega-3s can help … lift you out of depression.” This post links to a webpage on your website titled “Liposomal DHA, Omega-3 for … Dementia, Alzheimers.”
§ 321(p)]. New drugs may not be legally introduced or delivered for introduction into interstate commerce without prior approval from FDA, as described in sections 301(d) and 505(a) of the Act [21 U.S.C. §§ 331(d), 355(a)]. FDA approves a new drug on the basis of scientific data and information demonstrating that the drug is safe and effective.
§ 352(f)(1)] if the drug fails to bear adequate directions for its intended use(s). “Adequate directions for use” means directions under which a layperson can use a drug safely and for the purposes for which it is intended (21 C.F.R. § 201.5). Prescription drugs, as defined in section 503(b)(1)(A) of the Act [21 U.S.C. § 353(b)(1)(A)], can only be used safely at the direction, and under the supervision, of a licensed practitioner.
, Glutathione, Liposomal DHA – Ultimate Omega-3 Brain Support, Liposomal Methyl B12/Folate, NAC N-Acetyl-L-Cysteine, and Vectomega are intended for treatment of one or more diseases that are not amenable to self-diagnosis or treatment without the supervision of a licensed practitioner. Therefore, it is impossible to write adequate directions for a layperson to use your products safely for their intended purposes. Accordingly, 2-AEP Membrane Complex, Black Seed, Glutathione, Liposomal DHA – Ultimate Omega-3 Brain Support, Liposomal Methyl B12/Folate, NAC N-Acetyl-L-Cysteine, and Vectomega 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)].
Office of Compliance
Center for Food Safety and Applied Nutrition
John Gray’s Mars Venus LLC John Henderson Gray
13 Lyon Pl
Mill Valley CA 94941
This page was posted on February 21, 2019.