Alternative Health Experts LLC DBA Immunization Alternatives MARCS-CMS 605884 —
- Alternative Health Experts LLC DBA Immunization Alternatives
- Issuing Office:
- Center for Drug Evaluation and Research | CDER
Date: April 6, 2020
RE: Unapproved and Misbranded Products Related to Coronavirus Disease 2019 (COVID-19)
This is to advise you that the United States Food and Drug Administration (FDA) reviewed your websites at the Internet addresses www.immunizationalternatives.com and www.homeopathicremediesonline.com on March 24, 2020. We also reviewed your social media website at https://www.facebook.com/ImmunizationAlternatives/, where you direct consumers to your website, www.immunizationalternatives.com, to purchase your products. The FDA has observed that your website offers homeopathic drugs and dietary supplement products for sale in the United States and that these products are intended to mitigate, prevent, treat, diagnose, or cure COVID-19 in people. Based on our review, these products are unapproved new drugs sold in violation of section 505(a) of the Federal Food, Drug, and Cosmetic Act (FD&C Act), 21 U.S.C. § 355(a). Furthermore, these products are misbranded drugs under section 502 of the FD&C Act, 21 U.S.C. § 352. The introduction or delivery for introduction of these products into interstate commerce is prohibited under sections 301(a) and (d) of the FD&C Act, 21 U.S.C. § 331(a) and (d).
There is currently a global outbreak of respiratory disease caused by a novel coronavirus that has been named “severe acute respiratory syndrome coronavirus 2” (SARS-CoV-2). The disease caused by the virus has been named “Coronavirus Disease 2019” (COVID-19). On January 31, 2020, the Department of Health and Human Services (HHS) issued a declaration of a public health emergency related to COVID-19 and mobilized the Operating Divisions of HHS. In addition, on March 13, 2020, the President declared a national emergency in response to COVID-19. Therefore, FDA is taking urgent measures to protect consumers from certain products that, without approval or authorization by FDA, claim to mitigate, prevent, treat, diagnose, or cure COVID-19 in people. As described below, you sell products that are intended to mitigate, prevent, treat, diagnose or cure COVID-19 in people. We request that you take immediate action to cease the sale of such unapproved and unauthorized products for the mitigation, prevention, treatment, diagnosis, or cure of COVID-19.
Some examples of the claims on your website(s) that establish the intended use of your products and misleadingly represent them as safe and/or effective for the treatment or prevention of COVID-19 include:
- Under the webpage “HOMEOPROPHYLAXIS FOR CORONAVIRUS” you provide information about COVID-19 and describe “Homeoprophylaxis For Coronavirus Prevention and Homeopathic Remedies” [from your website https://immunizationalternatives.com/homeoprophylaxis-for-coronavirus/]
- You provide a “Recommendation Using Homeopathy to Prevent Coronavirus,” including numerous different products and links to purchase such products [from your website https://immunizationalternatives.com/homeoprophylaxis-for-coronavirus/]
- You provide “Top Homeopathic Remedies For Treatment Of Coronavirus Diagnosis or Symptoms,” including numerous different products and links to purchase such products [from your website https://immunizationalternatives.com/homeoprophylaxis-for-coronavirus/]
- “The following common homeopathic remedies are associated with the onset symptoms that may occur after contracting the Coronavirus (COVID-19) … Purchase a 200C Acute Remedy Kit with 50 remedies.” [from your website https://immunizationalternatives.com/homeoprophylaxis-for-coronavirus/]
- “Use of Nutritional And Herbal Supports For Coronavirus Prevention . . . #1 Vitamin C! . . . is proving to be successful in China for COVID-10 . . . Quercetin and Epigallocatechin Gallate . . . had the best inhibitory effects against SARS Coronavirus . . .” [from your website https://immunizationalternatives.com/homeoprophylaxis-for-coronavirus/]
- “Vitamin C for COVID-19” [from a March 12, 2020 post on your Social Media website https://www.facebook.com/ImmunizationAlternatives]
You should take immediate action to correct the violations cited in this letter. This letter is not meant to be an all-inclusive list of violations that exist in connection with your products or operations. It is your responsibility to ensure that the products you sell are in compliance with the FD&C Act and FDA's implementing regulations. We advise you to review your websites, product labels, and other labeling and promotional materials to ensure that you are not representing your products for a COVID-19 related use for which they have not been approved by FDA and that you do not make claims that misbrand the products in violation of the FD&C Act. Within 48 hours, please send an email to COVID-19-Task-Force-CDER@fda.hhs.gov describing the specific steps you have taken to correct these violations. Include an explanation of each step being taken to prevent the recurrence of violations, as well as copies of related documentation. Failure to immediately correct the violations cited in this letter may result in legal action, including, without limitation, seizure and injunction.
FDA is advising consumers not to purchase or use certain products that have not been approved, cleared, or authorized by FDA and that are being misleadingly represented as safe and/or effective for the treatment or prevention of COVID-19. Your firm will be added to a published list on FDA’s website of firms and websites that have received warning letters from FDA concerning the sale or distribution of COVID-19 related products in violation of the FD&C Act. This list can be found at http://www.fda.gov/consumers/health-fraud-scams/fraudulent-coronavirus-disease-covid-19-products. Once you have taken corrective actions to cease the sale of your unapproved and unauthorized products for the mitigation, prevention, treatment, diagnosis, or cure of COVID-19, and such actions have been confirmed by the FDA, the published list will be updated to indicate that your firm has taken appropriate corrective action.
If you cannot complete corrective action within 48 hours, state the reason for the delay and the time within which you will complete the corrections. If you believe that your products are not in violation of the FD&C Act, include your reasoning and any supporting information for our consideration.
If you are not located in the United States, please note that products that appear to be misbranded or unapproved new drugs are subject to detention and refusal of admission if they are offered for importation into the United States. We may advise the appropriate regulatory officials in the country from which you operate that FDA considers your product(s) referenced above to be unapproved and misbranded products that cannot be legally sold to consumers in the United States.
Please direct any inquiries to FDA at COVID-19-Task-Force-CDER@fda.hhs.gov.
Donald D. Ashley
Office of Compliance
Center for Drug Evaluation and Research
Food and Drug Administration
 As explained in the next paragraph, there is currently an outbreak of a respiratory disease named “Coronavirus Disease 2019” (COVID-19).
 Secretary of Health and Human Services Alex M Azar, Determination that a Public Health Emergency Exists. Jan. 31, 2020. (Accessible at https://www.phe.gov/emergency/news/healthactions/phe/Pages/2019-nCoV.aspx).
 President Donald J. Trump, Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19). Mar. 13, 2020. (Accessible at https://www.whitehouse.gov/presidential-actions/proclamation-declaring-national-emergency-concerning-novel-coronavirus-disease-covid-19-outbreak/).