As discussed in my iodine essay (FDA adverse events), iodine is a powerful health intervention as it eliminates cretinism and improves average IQ by a shocking magnitude. If this effect were possible for non-fetuses in general, it would be the best nootropic ever discovered, and so I looked at it very closely. Unfortunately, after going through ~20 experiments looking for ones which intervened with iodine post-birth and took measures of cognitive function, my meta-analysis concludes that: the effect is small and driven mostly by one outlier study. Once you are born, it’s too late. But the results could be wrong, and iodine might be cheap enough to take anyway, or take for non-IQ reasons. (This possibility was further weakened for me by an August 2013 blood test of TSH which put me at 3.71 uIU/ml, comfortably within the reference range of 0.27-4.20.)
Another traditional Chinese brain booster is Danggui-Shaoyao-San (DSS). It has been suggested that DSS has potent beneficial angiogenesis and neurogenesis effects that may make it a potential treatment for ischemic stroke therapy. DSS is also known to beneficially impact free radical-mediated neurological diseases, exhibit anti-inflammatory and antioxidant activities and reduce cell death in the hippocampus, thereby promoting greater emotional, memory-related and autonomic nervous system function. Currently, there is limited research on proper dosage, but you can learn more about DSS in this fantastic summary article on it’s interplay with Alzheimer’s.
The price is not as good as multivitamins or melatonin. The studies showing effects generally use pretty high dosages, 1-4g daily. I took 4 capsules a day for roughly 4g of omega acids. The jar of 400 is 100 days’ worth, and costs ~$17, or around 17¢ a day. The general health benefits push me over the edge of favoring its indefinite use, but looking to economize. Usually, small amounts of packaged substances are more expensive than bulk unprocessed, so I looked at fish oil fluid products; and unsurprisingly, liquid is more cost-effective than pills (but like with the powders, straight fish oil isn’t very appetizing) in lieu of membership somewhere or some other price-break. I bought 4 bottles (16 fluid ounces each) for $53.31 total (thanks to coupons & sales), and each bottle lasts around a month and a half for perhaps half a year, or ~$100 for a year’s supply. (As it turned out, the 4 bottles lasted from 4 December 2010 to 17 June 2011, or 195 days.) My next batch lasted 19 August 2011-20 February 2012, and cost $58.27. Since I needed to buy empty 00 capsules (for my lithium experiment) and a book (Stanovich 2010, for SIAI work) from Amazon, I bought 4 more bottles of 16fl oz Nature’s Answer (lemon-lime) at $48.44, which I began using 27 February 2012. So call it ~$70 a year.
This doesn’t fit the U-curve so well: while 60mg is substantially negative as one would extrapolate from 30mg being ~0, 48mg is actually better than 15mg. But we bought the estimates of 48mg/60mg at a steep price - we ignore the influence of magnesium which we know influences the data a great deal. And the higher doses were added towards the end, so may be influenced by the magnesium starting/stopping. Another fix for the missingness is to impute the missing data. In this case, we might argue that the placebo days of the magnesium experiment were identical to taking no magnesium at all and so we can classify each NA as a placebo day, and rerun the desired analysis:
Thanks to the many years of research in the field, we know now that what we eat can have a strong impact on our mental health. Not only can it protect us from developing Alzheimer's, but it's an act of self-care on its own. "Biology is all about harmony, about finding equilibrium and homeostasis," says Dr. Lisa, which is why her approach differs from food restrictions and focuses on minimizing intake of those foods that don't help us feel better. 
You would have heard this advice from top achievers in any field, “Work Smarter, not Harder.” Then why not extend the same philosophy in all areas of your life? Are you smarting from a situation wherein no matter how much you exercise, eat healthy, and sleep well, you still find it a struggle to focus and motivate yourself? If yes, you need smart help that is not hard on you. Try ‘Smart Drugs’, that could help you come out of your situation, by speeding up your thought process, boosting your memory, and making you more creative and productive.
These days, young, ambitious professionals prefer prescription stimulants—including methylphenidate (usually sold as Ritalin) and Adderall—that are designed to treat people with attention deficit hyperactivity disorder (ADHD) and are more common and more acceptable than cocaine or nicotine (although there is a black market for these pills). ADHD makes people more likely to lose their focus on tasks and to feel restless and impulsive. Diagnoses of the disorder have been rising dramatically over the past few decades—and not just in kids: In 2012, about 16 million Adderall prescriptions were written for adults between the ages of 20 and 39, according to a report in the New York Times. Both methylphenidate and Adderall can improve sustained attention and concentration, says Barbara Sahakian, professor of clinical neuropsychology at the University of Cambridge and author of the 2013 book Bad Moves: How Decision Making Goes Wrong, and the Ethics of Smart Drugs. But the drugs do have side effects, including insomnia, lack of appetite, mood swings, and—in extreme cases—hallucinations, especially when taken in amounts the exceed standard doses. Take a look at these 10 foods that help you focus.
For the moment, people looking for that particular quick fix have a limited choice of meds. But given the amount of money and research hours being spent on developing drugs to treat cognitive decline, Provigil and Adderall are likely to be joined by a bigger pharmacopoeia. Among the drugs in the pipeline are ampakines, which target a type of glutamate receptor in the brain; it is hoped that they may stem the memory loss associated with diseases like Alzheimer's. But ampakines may also give healthy people a palpable cognitive boost. A 2007 study of 16 healthy elderly volunteers found that 500mg of one particular ampakine "unequivocally" improved short-term memory, though it appeared to detract from episodic memory - the recall of past events. Another class of drugs, cholinesterase inhibitors, which are already being used with some success to treat Alzheimer's patients, have also shown promise as neuroenhancers. In one study the drug donepezil strengthened the performance of pilots on flight simulators; in another, of 30 healthy young male volunteers, it improved verbal and visual episodic memory. Several pharmaceutical companies are working on drugs that target nicotine receptors in the brain in the hope that they can replicate the cognitive uptick that smokers get from cigarettes.

The low-carb & high-fat diet (includes keto-diet) are not good for you because the brain needs glucose for fuel. It can burn fat. But, the brain’s preferred energy source is glucose. The key is to provide the brain with glucose without raising glucose/serum blood level. You do that by avoiding sugar and eating complex carbohydrates (fresh produce) that convert into glucose.
Apkarian and colleagues imaged the brains of 68 participants and gave them personality tests. The researchers then randomly assigned the participants to groups that either received no treatment, sugar pills or a pain-killing drug. Those given pills were not told if they received a placebo or an active drug. Participants took the treatment for two weeks, stopped for one week and then repeated this cycle.
A recent study at the University of Innsbruck in Austria found that participants that drank two cups of coffee per day improved memory, reaction time, and neuron signaling, more than the control. More notably, the 676 daily coffee drinker participants experienced less mental decline than nondrinkers over a ten-year period. In other words, bottoms up on your cup of Joe!
In 2011, as part of the Silk Road research, I ordered 10x100mg Modalert (5btc) from a seller. I also asked him about his sourcing, since if it was bad, it’d be valuable to me to know whether it was sourced from one of the vendors listed in my table. He replied, more or less, I get them from a large Far Eastern pharmaceuticals wholesaler. I think they’re probably the supplier for a number of the online pharmacies. 100mg seems likely to be too low, so I treated this shipment as 5 doses:
So, I thought I might as well experiment since I have it. I put the 23 remaining pills into gel capsules with brown rice as filling, made ~30 placebo capsules, and will use the one-bag blinding/randomization method. I don’t want to spend the time it would take to n-back every day, so I will simply look for an effect on my daily mood/productivity self-rating; hopefully Noopept will add a little on average above and beyond my existing practices like caffeine+piracetam (yes, Noopept may be as good as piracetam, but since I still have a ton of piracetam from my 3kg order, I am primarily interested in whether Noopept adds onto piracetam rather than replaces). 10mg doses seem to be on the low side for Noopept users, weakening the effect, but on the other hand, if I were to take 2 capsules at a time, then I’d halve the sample size; it’s not clear what is the optimal tradeoff between dose and n for statistical power.
Sometimes called smart drugs, brain boosters, or memory-enhancing drugs, the term "nootropics" was coined by scientist Dr. Corneliu E. Giurgea, who developed the compound piracetam as a brain enhancer, according to The Atlantic. The word is derived from the Greek noo, meaning mind, and trope, which means "change" in French. In essence, all nootropics aim to change your mind by enhancing functions like memory or attention.

Aside from the obvious pleasure some derive from this traditional combo, are there any actual benefits to simultaneously smoking and drinking coffee? One study in the Journal of Epidemiology and Community Health definitely concludes that the answer is yes. In the study, researchers analyzed 497 men and women with confirmed cases of papilloma, carcinoma and polyps of the bladder. All study participants, along with 1,113 control cases, were interviewed to determine the use of tobacco, exposure to secondhand smoke and coffee drinking.

In that year, Dr. Corneliu Giurgea, a Romanian scientist, synthesized piracetam for the first time. Piracetam is classified as a nootropic, although the term nootropic was not used until 1972.[2] Dr. Giurgea coined the term “nootropic” by combining the Greek words for mind (nous) and bend (trepein).  Nootropic literally translates into the phrase “mind bender.”
Dr. Mosconi: I love apples. When I’m at the office though, I’ll bring homemade trail mix [made with] higher quality dried fruit, nuts and seeds. [It's] packed with brain-essential nutrients that come from goji berries, Brazil nuts, walnuts, cacao nibs, pistachios, hemp hearts and  more. Plus, I drink plenty of rose water throughout the day, which is very anti-inflammatory.
The chemicals he takes, dubbed nootropics from the Greek “noos” for “mind”, are intended to safely improve cognitive functioning. They must not be harmful, have significant side-effects or be addictive. That means well-known “smart drugs” such as the prescription-only stimulants Adderall and Ritalin, popular with swotting university students, are out. What’s left under the nootropic umbrella is a dizzying array of over-the-counter supplements, prescription drugs and unclassified research chemicals, some of which are being trialled in older people with fading cognition.
This would be a very time-consuming experiment. Any attempt to combine this with other experiments by ANOVA would probably push the end-date out by months, and one would start to be seriously concerned that changes caused by aging or environmental factors would contaminate the results. A 5-year experiment with 7-month intervals will probably eat up 5+ hours to prepare <12,000 pills (active & placebo); each switch and test of mental functioning will probably eat up another hour for 32 hours. (And what test maintains validity with no practice effects over 5 years? Dual n-back would be unusable because of improvements to WM over that period.) Add in an hour for analysis & writeup, that suggests >38 hours of work, and 38 \times 7.25 = 275.5. 12,000 pills is roughly $12.80 per thousand or $154; 120 potassium iodide pills is ~$9, so \frac{365.25}{120} \times 9 \times 5 = 137.
As I am not any of the latter, I didn’t really expect a mental benefit. As it happens, I observed nothing. What surprised me was something I had forgotten about: its physical benefits. My performance in Taekwondo classes suddenly improved - specifically, my endurance increased substantially. Before, classes had left me nearly prostrate at the end, but after, I was weary yet fairly alert and happy. (I have done Taekwondo since I was 7, and I have a pretty good sense of what is and is not normal performance for my body. This was not anything as simple as failing to notice increasing fitness or something.) This was driven home to me one day when in a flurry before class, I prepared my customary tea with piracetam, choline & creatine; by the middle of the class, I was feeling faint & tired, had to take a break, and suddenly, thunderstruck, realized that I had absentmindedly forgot to actually drink it! This made me a believer.

The original magnesium l-threonate caused me no apparent problems by the time I finished off the powder and usage correlated with better days, further supporting the hypothesis that magnesium helps it. But l-threonate would be difficult to cap (and hence blind self-experiment) and is ruinously expensive on a per-dose basis. So I looked around for alternatives for the followup; one of the most common compounds suggested was the citrate form because it is reasonably well-absorbed and causes fewer digestive problems, so I could just take that. Magnesium oxide is widely available it looks cheap, but the absorption/bioavailability problem makes it unattractive: at a 3:5 ratio, an estimate of 4% absorption, a ZMA formulation of an impressive-sounding 500mg would be 500 \times \frac{3}{5} \times 0.04 = 12mg or a small fraction of RDAs for male adults like 400mg elemental. (Calcium shouldn’t be a problem since I get 220mg of calcium from my multivitamin and I enjoy dairy products daily.)
You have probably heard and you already love the term “soul food.” You should know that there’s “brain food” too. Natural supplements are the best way to express your gratitude for all the hard work your brain does for you around the clock. These products aren’t reserved only for the elderly users. On the contrary, if you start using them while you’re still young and sharp, you can ensure the proper protection against all those age-related mental deterioration processes.
Including comprehensive lists of what to eat and what to avoid, a detailed quiz that will tell you where you are on the brain health spectrum, and 24 mouth-watering brain-boosting recipes that grow out of Dr. Mosconi’s own childhood in Italy, Brain Food gives us the ultimate plan for a healthy brain. Brain Food will appeal to anyone looking to improve memory, prevent cognitive decline, eliminate brain fog, lift depression, or just sharpen their edge.
Dr. Lisa Mosconi, PhD, INHC, is the associate director of the Alzheimer's Prevention Clinic at Weill Cornell Medical College (WCMC)/NewYork-Presbyterian Hospital, where she was recruited as an associate professor of Neuroscience in Neurology. She also is an adjunct faculty member in the Department of Psychiatry at NYU School of Medicine, in the Department of Nutrition at NYU Steinhardt School of Nutrition and Public Health, and in the Departments of Neurology and Nuclear Medicine at the University of Florence (Italy). Formerly, Dr. Mosconi founded and was the director of the Nutrition & Brain Fitness Lab at New York University School of Medicine (NYU), and an assistant professor in the NYU Department of Psychiatry, where she served as the director of the Family History of Alzheimer's disease research program. Dr. Mosconi holds a dual PhD degree in Neuroscience and Nuclear Medicine from the University of Florence, Italy, and is a board certified integrative nutritionist and holistic healthcare practitioner. She is well known for her research on the early detection of Alzheimer's disease and is passionately interested in the mitigation and prevention of memory loss through lifestyle modifications including diet, nutrition, and physical and intellectual fitness.
Seriously. Every single thing you experience comes through your brain. It create the fabric of your reality, and by the same token, the energy your brain makes is what allows you to shape that reality. Work, relationships, success, happiness — everything depends on your brain, and building a stronger one will trigger upgrades that extend across every aspect of your life.
Last summer, I visited Phillips in the high desert resort town of Bend, Oregon, where he lives with his wife, Kathleen, and their two daughters, Ivy and Ruby. Phillips, who is now 36, took me for coffee at a cheery café called Thump. Wearing shorts, flip-flops and a black T-shirt, he said: "Poker is about sitting in one place, watching your opponents for a long time, and making better observations about them than they make about you." With Provigil, he "could process all the information about what was going on at the table and do something about it". Though there is no question that Phillips became much more successful at poker after taking neuroenhancers, I asked him if his improvement could be explained by a placebo effect, or by coincidence. He doubted it, but allowed that it could. Still, he said, "there's a sort of clarity I get with Provigil. With Adderall, I'd characterise the effect as correction - correction of an underlying condition. Provigil feels like enhancement." And, whereas Adderall made him "jittery", Provigil's effects were "completely limited to my brain". He had "zero difficulty sleeping".
Oxiracetam is one of the 3 most popular -racetams; less popular than piracetam but seems to be more popular than aniracetam. Prices have come down substantially since the early 2000s, and stand at around 1.2g/$ or roughly 50 cents a dose, which was low enough to experiment with; key question, does it stack with piracetam or is it redundant for me? (Oxiracetam can’t compete on price with my piracetam pile stockpile: the latter is now a sunk cost and hence free.)
However, normally when you hear the term nootropic kicked around, people really mean a “cognitive enhancer” — something that does benefit thinking in some way (improved memory, faster speed-of-processing, increased concentration, or a combination of these, etc.), but might not meet the more rigorous definition above.  “Smart drugs” is another largely-interchangeable term.
Professor David O Kennedy published a book in 2014 called Plants and the Human Brain. In his book he summarizes the last 15 years of research into cognitive nutrition, including the work he's done with colleagues at the Brain Performance Nutrition Research Center at Northumbria University. It's a great read and a good guide to what sorts of herbs and other plants to include in our weekly diet and it is all based on hard science rather than mere assertion or trendy but unsubstantiated beliefs.
Broccoli is great source of vitamin K, which is known to enhance cognitive function and improve brainpower. Researchers have reported that because broccoli is high in compounds called glucosinolates, it can slow the breakdown of the neurotransmitter, acetylcholine, which we need for the central nervous system to perform properly and to keep our brains and our memories sharp. Low levels of acetylcholine are associated with Alzheimer's.
It’s basic economics: the price of a good must be greater than cost of producing said good, but only under perfect competition will price = cost. Otherwise, the price is simply whatever maximizes profit for the seller. (Bottled water doesn’t really cost $2 to produce.) This can lead to apparently counter-intuitive consequences involving price discrimination & market segmentation - such as damaged goods which are the premium product which has been deliberately degraded and sold for less (some Intel CPUs, some headphones etc.). The most famous examples were railroads; one notable passage by French engineer-economist Jules Dupuit describes the motivation for the conditions in 1849:
But before you go lock yourself in a dark, quiet room in order to prevent this overburden on your brain, you should know that there are scientifically researched compounds designed to amplify cognitive function and help your brain deal with this excess load, or simply get you through a period of sleep deprivation, increased creativity or work demands, the need to pull an all-nighter or an intense bout of work or study.
Vitamin D is probably the most important supplement you can take, and one of the best brain food. It acts on more than over 1,000 different genes and is a substrate for testosterone, progesterone, estradiol, and other  hormones.[1] It also influences inflammation and brain calcium absorption.[2] No surprise that optimal vitamin D levels are linked to stronger cognitive function and slower brain aging.[3][4]
Reason: More than 50 percent of your brain is comprised of DHA! Among a big group of elderly Americans, those with the highest blood levels of DHA were about half as apt to develop dementia and 39% as apt to develop Alzheimer’s as those with lower blood levels of DHA over a nine-year period. The top 25% of those with the highest blood DHA got about 180 mg DHA a day or three servings of fish a week, researchers said. In this study, the other major fatty acid in fish oil. EPA had no effect.

There are a ton of great rosemary snack options. Personally, I always keep some flavored natural sea salts in my desk to spice up my snacks and meals at the office. Here’s a great option for rosemary flavored sea salt. Another great choice is the Parmesan Rosemary Popcorn from Quinn’s Popcorn. They never use GMO corn, coatings or chemicals on the bag, or any other scary stuff found in traditional microwave popcorn. This is truly microwave popcorn reinvented.
Reason: Acetyl-L-carnitine can protect the brain from neurotoxicity. It can also ward off oxygen deprivation. Acetyl-L-carnitine can even preserve cells energy-producing mitochondria. Plus, it can rejuvenate mental and physical function. Dosages for studies have been in the 1,500 – 4,000 mg range. These are divided into two or three doses. However, we recommend no more than 1,000 mg of acetyl-L-carnitine a day without medical supervision.
The evidence? In small studies, healthy people taking modafinil showed improved planning and working memory, and better reaction time, spatial planning, and visual pattern recognition. A 2015 meta-analysis claimed that “when more complex assessments are used, modafinil appears to consistently engender enhancement of attention, executive functions, and learning” without affecting a user’s mood. In a study from earlier this year involving 39 male chess players, subjects taking modafinil were found to perform better in chess games played against a computer.
For now, instead of reaching for a designer supplement, you're better off taking a multivitamin, according to some experts. It's well known that antioxidants like vitamins C and E protect cells from damage by disarming free radicals. Brain cells are especially vulnerable to these troublemakers because the brain generates more free radicals per gram of tissue than any other organ. Antioxidants also protect neurons by keeping blood vessels supple and open, ensuring the flow of nutrients to the brain.
The research literature, while copious, is messy and varied: methodologies and devices vary substantially, sample sizes are tiny, the study designs vary from paper to paper, metrics are sometimes comically limited (one study measured speed of finishing a RAPM IQ test but not scores), blinding is rare and unclear how successful, etc. Relevant papers include Chung et al 2012, Rojas & Gonzalez-Lima 2013, & Gonzalez-Lima & Barrett 2014. Another Longecity user ran a self-experiment, with some design advice from me, where he performed a few cognitive tests over several periods of LLLT usage (the blocks turned out to be ABBA), using his father and towels to try to blind himself as to condition. I analyzed his data, and his scores did seem to improve, but his scores improved so much in the last part of the self-experiment I found myself dubious as to what was going on - possibly a failure of randomness given too few blocks and an temporal exogenous factor in the last quarter which was responsible for the improvement.
However, they fell short in several categories. The key issue with their product is that it does not contain DHA Omega 3 and the other essential vitamins and nutrients needed to support the absorption of Huperzine A and Phosphatidylserine. Without having DHA Omega 3 it will not have an essential piece to maximum effectiveness. This means that you would need to take a separate pill of DHA Omega 3 and several other essential vitamins to ensure you are able to reach optimal memory support. They also are still far less effective than our #1 pick’s complete array of the 3 essential brain supporting ingredients and over 30 supporting nutrients, making their product less effective.
Can brain enhancing pills actually improve memory? This is a common question and the answer varies, depending on the product you are considering. The top 25 brain enhancement supplements appear to produce results for many users. Research and scientific studies have demonstrated the brain boosting effects of nootropic ingredients in the best quality supplements. At Smart Pill Guide, you can read nootropics reviews and discover how to improve memory for better performance in school or at work.
Encouraged by TruBrain’s magnesium & my magnesium l-threonate use, I design and run a blind random self-experiment to see whether magnesium citrate supplementation would improve my mood or productivity. I collected ~200 days of data at two dose levels. The analysis finds that the net effect was negative, but a more detailed look shows time-varying effects with a large initial benefit negated by an increasingly-negative effect. Combined with my expectations, the long half-life, and the higher-than-intended dosage, I infer that I overdosed on the magnesium. To verify this, I will be running a followup experiment with a much smaller dose.
Nootropics are classically defined as something that a) improves brain health, and b) does no harm. So, while many treatments being advertised online and on TV can be classified as nootropics, some of them don’t fit the bill because of the dangerous and damaging side effects they also confer upon the unwary consumer. In fact, most of the results you might get from searching ‘best brain pills’ are similarly not that great, let alone the best.

Autism BDNF Brain brain fuel brain health Brain Injury Cholesterol choline DAI DHA Diabetes digestion Exercise Fat Functional Medicine gastric Gluten gut-brain Gut Brain Axis gut health Health intestinal permeability keto Ketogenic leaky Gut Learning Medicine Metabolism Music Therapy neurology Neuroplasticity neurorehabilitation Nutrition omega Paleo Physical Therapy Recovery Science second brain superfood synaptogenesis TBI Therapy tube feed uridine
Too much caffeine may be bad for bone health because it can deplete calcium. Overdoing the caffeine also may affect the vitamin D in your body, which plays a critical role in your body’s bone metabolism. However, the roles of vitamin D as well as caffeine in the development of osteoporosis continue to be a source of debate. Significance: Caffeine may interfere with your body’s metabolism of vitamin D, according to a 2007 Journal of Steroid Biochemistry & Molecular Biology study. You have vitamin D receptors, or VDRs, in your osteoblast cells. These large cells are responsible for the mineralization and synthesis of bone in your body. They create a sheet on the surface of your bones. The D receptors are nuclear hormone receptors that control the action of vitamin D-3 by controlling hormone-sensitive gene expression. These receptors are critical to good bone health. For example, a vitamin D metabolism disorder in which these receptors don’t work properly causes rickets.

You don’t need a therapist and certainly not a shaman. Just find someone you trust. It doesn’t matter the plant or what is derived from it, whether it’s LSD, shrooms, or mescaline via legal San Pedro cactus; it’s all the same experience, essentially indistinguishable. Just be sure & take enough. If it’s blotter acid, you need about 5 hits (Leary said that if you don’t have an ego-death ( read: religious) experience, you didn’t take enough, which he suggested to be at least 400 micrograms). Mushrooms vary. Typically, in excess of a few grams, to achieve this same state. San Pedro, though variable, too, requires 12-18 inches or a few (bitter-tasting) dried “stars” (x-section, thin-sliced, in the oven @ 150 degrees, until dry like snack chips).
"Instead of messing it up, we should be appreciating something that nature has taken years to optimize," Dr. Lisa mentions. But, we aren't messing it up voluntarily or, at the very least, on any conscious or malicious level. She attributes our disregard for neuro-nutrition to a series of factors, which include the portion size of meals, how parents don't have the time to cook or teach children how to eat healthily, the big influence of cafeteria food, and our "always on the go" culture. According to her, this leads us to unconsciously choose meals which are poor quality and high in sugars, a deathly combination for our brains.
According to the US Food and Drug Administration, "Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. [...] Accordingly, these products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling."[33]
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