News & Analysis as of

Federal Food Drug and Cosmetic Act (FFDCA) GRAS Food and Drug Administration (FDA)

Husch Blackwell LLP

FDA Allows Longstanding MOU with AAFCO To Expire

Husch Blackwell LLP on

On August 2, 2024, the Association of American Feed Control Officials (“AAFCO”) announced that its Memorandum of Understanding 225-07-7001 (the “MOU”) with the U.S. Food and Drug Administration (“FDA”) outlining the AAFCO...more

Rivkin Radler LLP

The Case of ‘Gas Station Heroin’

Rivkin Radler LLP on

Is It Necessary for Congress to Amend the FD&C Act for FDA to Have the Authority to Prohibit Tianeptine’s Sale? If the answer to this question is “no,” why are bills being introduced into Congress to give the U.S. Food and...more

Foley & Lardner LLP

My Healthy Food Product is Ready to Go to Market – What About its Packaging?

Foley & Lardner LLP on

After formulating an exciting new healthy food or beverage, the packaging it comes in may feel like an afterthought.  It should not be.   Food packaging has become an increasingly hot topic among federal and state regulators,...more

Foley & Lardner LLP

Bringing a New Healthy Food Ingredient to Market: Understanding the Regulatory Pathways

Foley & Lardner LLP on

Whether formulating a new food or developing a novel ingredient, a critical first step is understanding the regulatory framework for bringing a new ingredient (or a food containing a new ingredient) to the market.  This...more

Husch Blackwell LLP

The Future of Functional Foods

Husch Blackwell LLP on

Following the social isolation and public health concerns associated with the COVID-19 pandemic, many Americans reevaluated their health and wellness priorities, creating new opportunities for food systems companies to...more

Perkins Coie

FDA Releases Public Inventory of Unapproved Food Additives

Perkins Coie on

The U.S. Food and Drug Administration (FDA) released a public inventory on July 12, 2023, of certain food ingredients that the agency has determined are unsafe because they are unapproved food additives that are not Generally...more

Hogan Lovells

Homeopathic drug product makers warned to follow FDA premarket and GMP rules

Hogan Lovells on

Last month, the U.S. Food and Drug Administration (FDA) issued the final guidance “Homeopathic Drug Products,” which describes the agency’s approach toward prioritizing regulatory actions against homeopathic products that it...more

Vicente LLP

High-THC Hemp Edibles Are Dangerous and Potentially Deadly: A Cautionary Tale in Minnesota

Vicente LLP on

On December 5, 2022, the Minnesota Board of Pharmacy filed a lawsuit against three affiliated Minnesota hemp companies seeking condemnation and destruction of several million dollars worth of gummy edibles. Ironically named...more

Hogan Lovells

FDA issues notable new round of warning letters involving foods with added CBD

Hogan Lovells on

On November 16, 2022, the United States Food and Drug Administration (FDA) issued Warning Letters to five companies that market food and beverage products containing cannabidiol (CBD). FDA takes the position that the...more

Vicente LLP

FDA Enforcement Action Targeted at Hemp-Derived Delta-8 Products

Vicente LLP on

On May 4, 2022, the FDA issued five warning letters to companies for selling products containing hemp-derived Delta-8 THC. Notably, this is the first time the FDA has issued warning letters specifically for Delta-8 products....more

Vicente LLP

Financing Adaptogenic Mushroom Companies: Seven Basic Regulatory Points to Understand

Vicente LLP on

Aside from a small number of companies the FDA has permitted to pursue the development of psilocybin therapies (e.g., Compass), the majority of psychedelic mushroom sales in the U.S. currently violate both state and federal...more

Hogan Lovells

Federal Court Sides with FDA and Upholds GRAS Rule

Hogan Lovells on

The U.S. District Court for the Southern District of New York granted the U.S. Food and Drug Administration’s (FDA or the Agency) motion for summary judgment on September 30, 2021, against claims brought by a group of...more

King & Spalding

Selling CBD-Infused Products Might Be Riskier Than You Think

King & Spalding on

The global cannabidiol (CBD) market size is expected to reach USD 13.4 billion by 2028. And yet a large part of that market—CBD-infused food, beverages, and dietary supplements—consists of unlawful sales. This article...more

Morgan Lewis - Well Done

Chocolate Cicadas and Mealworm Mints: Will FDA Spit Out Guidance for Edible Insects?

The month of May was buzzing with good news for the edible insect industry, but this emerging food trend still faces regulatory uncertainty in the United States....more

McDermott Will & Emery

Florida Federal District Court Rules GRAS Regulation Preempts Florida Statute Criminalizing Ingredient

McDermott Will & Emery on

In an important ruling dismissing a proposed class action, the US District Court for the Southern District of Florida ruled that the US Food and Drug Administration’s (FDA’s) generally recognized as safe (GRAS) regulation...more

Akin Gump Strauss Hauer & Feld LLP

FDA Explains Current Thinking on CBD and Issues Targeted Warning Letters

On November 25, the Food and Drug Administration (FDA) issued 15 warning letters to companies selling products containing hemp-derived cannabidiol (CBD) and released a summary of its approach to the regulation of CBD...more

Mintz - Health Care Viewpoints

First Indicators of FDA’s Policy Decision on CBD and Cannabis-Derived Ingredients: “Only Limited Data” and “Real Risks”

We have previously blogged about the Food and Drug Administration’s year of listening and information gathering related to products containing cannabis or cannabis-derived compounds since the 2018 Farm Bill removed “hemp”...more

Perkins Coie

FDA Declines to Conclude CBD is Safe and Sends Flurry of Warning Letters

Perkins Coie on

On November 25, 2019, the U.S. Federal Drug Administration (FDA) took several significant actions regarding sellers of products containing cannabidiol (CBD). The FDA announced that it cannot conclude that CBD is “generally...more

McDermott Will & Emery

Learnings from the FDA Hearing on Cannabis and Cannabis-Derived Compounds

On Friday May 31, 2019, the Food and Drug Administration (FDA) held a public hearing on the topic of cannabis or cannabis-derived compounds. The FDA held the hearing to gather information regarding the safety risks and health...more

McDermott Will & Emery

TTB’s Take on Alcohol Beverages Infused with Cannabidiol

McDermott Will & Emery on

On April 25, 2019, TTB published Industry Circular 2019-1. It addresses the hot topic of alcohol beverages (especially beer) infused with hemp-derived ingredients–with cannabidiol (CBD) as the clear focus of industry...more

Morgan Lewis

Lawsuit Challenges GRAS Rule on Food Substance Safety

Morgan Lewis on

Public interest groups challenge FDA’s “Generally Recognized as Safe” Rule as failing to ensure food ingredients are safe for consumers....more

BCLP

FDA Releases Final Rule Allowing Voluntary Risk Reviews of Food Additives to Continue

BCLP on

The Food and Drug Administration (FDA) says its final rule allowing outside groups to evaluate food additive risks will streamline its “Generally Recognized as Safe” (GRAS) reviews. The agency recently released its GRAS...more

Faegre Drinker Biddle & Reath LLP

FDA Rule Formalizes Voluntary GRAS Notification System for Substances Added to Food

The U.S. Food and Drug Administration (FDA) has released its final rule “Substances Generally Recognized as Safe” (due for publication on August 17, 2016). Under the Federal Food, Drug, and Cosmetic Act, GRAS substances are...more

Womble Bond Dickinson

FDA Gives Food Industry Three Years to Phase Out Partially Hydrogenated Oils from Food Products

Womble Bond Dickinson on

On June 16, 2015, the Food and Drug Administration ("FDA") issued a declaratory order, requiring a phasing out of the use of partially hydrogenated oils ("PHOs"). In its order, the FDA stated that partially hydrogenated oils...more

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