Jump up ^ Weyandt LL, Oster DR, Marraccini ME, Gudmundsdottir BG, Munro BA, Zavras BM, Kuhar B (September 2014). "Pharmacological interventions for adolescents and adults with ADHD: stimulant and nonstimulant medications and misuse of prescription stimulants". Psychol. Res. Behav. Manag. 7: 223–249. doi:10.2147/PRBM.S47013. PMC 4164338. PMID 25228824.
A young man I'll call Alex recently graduated from Harvard. As a history major, Alex wrote about a dozen papers a term. He also ran a student organisation, for which he often worked more than 40 hours a week; when he wasn't working, he had classes. Weeknights were devoted to all the schoolwork he couldn't finish during the day, and weekend nights were spent drinking with friends and going to parties. "Trite as it sounds," he told me, it seemed important to "maybe appreciate my own youth". Since, in essence, this life was impossible, Alex began taking Adderall to make it possible.
Please browse our website to learn more about how to enhance your memory. Our blog contains informative articles about the science behind nootropic supplements, specific ingredients, and effective methods for improving memory. Browse through our blog articles and read and compare reviews of the top rated natural supplements and smart pills to find everything you need to make an informed decision.

Takao Hensch, a Harvard professor of cellular biology and part of a Boston Children’s Hospital team, found that the drug encouraged the brain to learn new skills as quickly as the sponge-like brain of an infant in her patient Shannon, an otherwise normal 14-year-old girl who suffers from extremely poor eyesight brought on by amblyopia, commonly known as lazy eye. In a matter of months, the drug helped Shannon’s brain relearn how to use her eye which resulted in markedly improved vision.


Began double-blind trial. Today I took one pill blindly at 1:53 PM. at the end of the day when I have written down my impressions and guess whether it was one of the Adderall pills, then I can look in the baggy and count and see whether it was. there are many other procedures one can take to blind oneself (have an accomplice mix up a sequence of pills and record what the sequence was; don’t count & see but blindly take a photograph of the pill each day, etc.) Around 3, I begin to wonder whether it was Adderall because I am arguing more than usual on IRC and my heart rate seems a bit high just sitting down. 6 PM: I’ve started to think it was a placebo. My heart rate is back to normal, I am having difficulty concentrating on long text, and my appetite has shown up for dinner (although I didn’t have lunch, I don’t think I had lunch yesterday and yesterday the hunger didn’t show up until past 7). Productivity wise, it has been a normal day. All in all, I’m not too sure, but I think I’d guess it was Adderall with 40% confidence (another way of saying placebo with 60% confidence). When I go to examine the baggie at 8:20 PM, I find out… it was an Adderall pill after all. Oh dear. One little strike against Adderall that I guessed wrong. It may be that the problem is that I am intrinsically a little worse today (normal variation? come down from Adderall?).

The effects of piracetam on healthy volunteers have been studied even less than those of Adderall or modafinil. Most peer-reviewed studies focus on its effects on dementia or on people who have suffered a seizure or a concussion. Many of the studies that look at other neurological effects were performed on rats and mice. Piracetam's mechanisms of action are not understood, though it may increase levels of the neurotransmitter acetylcholine. In 2008 a committee of the British Academy of Medical Sciences noted that many of the clinical trials of piracetam for dementia were methodologically flawed. Another published review of the available studies of the drug concluded that the evidence "does not support the use of piracetam in the treatment of people with dementia or cognitive impairment", but suggested that further investigation might be warranted. I asked Seltzer if he thought he should wait for scientific ratification of piracetam. He laughed. "I don't want to," he said. "Because it's working."

2 commenters point out that my possible lack of result is due to my mistaken assumption that if nicotine is absorbable through skin, mouth, and lungs it ought to be perfectly fine to absorb it through my stomach by drinking it (rather than vaporizing it and breathing it with an e-cigarette machine) - it’s apparently known that absorption differs in the stomach.

Recently I spoke on the phone with Barbara Sahakian, a clinical neuropsychologist at Cambridge University and the co-author of a 2007 article in Nature entitled "Professor's Little Helper". Sahakian, who also consults for several pharmaceutical companies, and her co-author, Sharon Morein-Zamir, reported that a number of their colleagues were using prescription drugs like Adderall and Provigil. Because the drugs are easy to buy online, they wrote, it would be difficult to stop their spread: "The drive for self-enhancement of cognition is likely to be as strong if not stronger than in the realms of 'enhancement' of beauty and sexual function." (In places like Cambridge, at least.)


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".
Seltzer's decision to take piracetam was based on his own online reading, which included medical-journal abstracts. He hadn't consulted a doctor. Since settling on a daily regime of supplements, he had sensed an improvement in his intellectual work and his ability to engage in stimulating conversation. He continued: "I feel I'm better able to articulate my thoughts. I'm sure you've been in the zone - you're having a really exciting debate with somebody, your brain feels alive. I feel that more. But I don't want to say that it's this profound change."
Just like throughout pregnancy, nutritional needs after birth, especially if breastfeeding, are incredibly important. The healthier the diet, the easier it will be to sustain the energy needed to take care of a newborn. Research shows that a breastfeeding mother needs an extra 300-500 calories a day, from food that is rich in the right macro and micronutrients to nourish both mother and baby (3). For example, nutrients such as B vitamins have shown to be important in supporting the mother in ensuring she has enough energy to meet the demands of lactation (4). These nutrients can be found in green leafy vegetables, wholegrains and good sources of animal protein. 
We already knew that rosemary oil has a variety of benefits, but did you know that the herb does, too? Carnosic acid, one of the main ingredients in rosemary, helps protect the brain from neurodegeneration. It does this by protecting the brain against chemical free radicals, which are linked to neurodegeneration, Alzheimer’s, strokes and normal aging in the brain. (10)
There is no official data on their usage, but nootropics as well as other smart drugs appear popular in the Silicon Valley. “I would say that most tech companies will have at least one person on something,” says Noehr. It is a hotbed of interest because it is a mentally competitive environment, says Jesse Lawler, a LA based software developer and nootropics enthusiast who produces the podcast Smart Drug Smarts. “They really see this as translating into dollars.” But Silicon Valley types also do care about safely enhancing their most prized asset – their brains – which can give nootropics an added appeal, he says.

2ml is supposed to translate to 24mg, which is a big dose. I do not believe any of the commercial patches go much past that. I asked Wedrifid, whose notes inspired my initial interest, and he was taking perhaps 2-4mg, and expressed astonishment that I might be taking 24mg. (2mg is in line with what I am told by another person - that 2mg was so much that they actually felt a little sick. On the other hand, in one study, the subjects could not reliably distinguish between 1mg and placebo25.) 24mg is particularly troubling in that I weigh ~68kg, and nicotine poisoning and the nicotine LD50 start, for me, at around 68mg of nicotine. (I reflected that the entire jar could be a useful murder weapon, although nicotine presumably would be caught in an autopsy’s toxicology screen; I later learned nicotine was an infamous weapon in the 1800s before any test was developed. It doesn’t seem used anymore, but there are still fatal accidents due to dissolved nicotine.) The upper end of the range, 10mg/kg or 680mg for me, is calculated based on experienced smokers. Something is wrong here - I can’t see why I would have nicotine tolerance comparable to a hardened smoker, inasmuch as my maximum prior exposure was second-hand smoke once in a blue moon. More likely is that either the syringe is misleading me or the seller NicVape sold me something more dilute than 12mg/ml. (I am sure that it’s not simply plain water; when I mix the drops with regular water, I can feel the propylene glycol burning as it goes down.) I would rather not accuse an established and apparently well-liked supplier of fraud, nor would I like to simply shrug and say I have a mysterious tolerance and must experiment with doses closer to the LD50, so the most likely problem is a problem with the syringe. The next day I altered the procedure to sucking up 8ml, squirting out enough fluid to move the meniscus down to 7ml, and then ejecting the rest back into the container. The result was another mild clean stimulation comparable to the previous 1ml days. The next step is to try a completely different measuring device, which doesn’t change either.


Of course learning, working memory and cognitive control represent just a few aspects of thinking. Farah concluded that studies looking at other kinds of cognition - verbal fluency, for instance - were too few and too contradictory to tell us much. Both Chatterjee and Farah have wondered whether drugs that heighten users' focus might dampen their creativity. After all, some of our best ideas come to us not when we sit down at a desk but rather when we're in the shower or walking the dog - letting our minds roam. Jimi Hendrix reported that the inspiration for "Purple Haze" came to him in a dream; the chemist Friedrich August Kekule claimed that he discovered the ring structure of benzene during a reverie in which he saw the image of a snake biting its tail. Farah told me: "There is some evidence that suggests that individuals who are better able to focus on one thing and filter out distractions tend to be less creative.
Not long ago I met Anjan Chatterjee, a neurologist at the University of Pennsylvania, in his office at the labyrinthine Penn hospital complex. Chatterjee's main research interests are in subjects like the neurological basis of spatial understanding, but in the past few years, as he has heard more about students taking cognitive enhancers, he has begun writing about the ethical implications of such behaviour. In 2004 he coined the term "cosmetic neurology" to describe the practice of using drugs developed for recognised medical conditions to strengthen ordinary cognition. Chatterjee worries about cosmetic neurology, but he thinks that it will eventually become as acceptable as cosmetic surgery; in fact with neuroenhancement it's harder to argue that it's frivolous. As he notes in a 2007 paper: "Many sectors of society have winner-take-all conditions in which small advantages produce disproportionate rewards." At school and at work, the usefulness of being "smarter", needing less sleep and learning more quickly is "abundantly clear". In the near future, he predicts, some neurologists will refashion themselves as "quality-of-life consultants" whose role will be "to provide information while abrogating final responsibility for these decisions to patients". The demand is certainly there: from an ageing population that won't put up with memory loss; from overwrought parents bent on giving their children every possible edge; from anxious employees in an efficiency-obsessed, BlackBerry-equipped office culture where work never really ends.
Sure, you could certainly swallow too much St. John’s Wort and create the same type of serotonin or neurotransmitter issues you could create with a synthetic smart drug, but it’s far more difficult to harm yourself with a nootropic compared to a synthetic smart drug. Although synthetic, laboratory-designed nootropics do indeed exist, even those are not as harsh on the biology as a smart drug and have a mechanism of action that is a bit more natural. Let’s begin with the more natural nootropics.

Most people I talk to about modafinil seem to use it for daytime usage; for me that has not ever worked out well, but I had nothing in particular to show against it. So, as I was capping the last of my piracetam-caffeine mix and clearing off my desk, I put the 4 remaining Modalerts pills into capsules with the last of my creatine powder and then mixed them with 4 of the theanine-creatine pills. Like the previous Adderall trial, I will pick one pill blindly each day and guess at the end which it was. If it was active (modafinil-creatine), take a break the next day; if placebo (theanine-creatine), replace the placebo and try again the next day. We’ll see if I notice anything on DNB or possibly gwern.net edits.


Back home, I contacted Aubrey Marcus, whose company Onnit Labs produces Alpha Brain. He attributed my lucid dreaming to increased levels of the neurotransmitter acetylcholine, which enhances REM dreaming. Alpha Brain has two ingredients that boost acetylcholine levels: GPC choline, which the body converts to acetylcholine, and Huperzine A, an alkaloid derived from Chinese club moss, also known as Huperzia serrata. "Huperzine A disarms the enzyme that naturally breaks down acetylcholine," Marcus said. "So while the GPC choline is being converted to acetylcholine, the Huperzine A is keeping it from disappearing. It's like plugging the drain and turning on the faucet."

Even the best of today’s nootropics only just barely scratch the surface. You might say that we are in the “Nokia 1100” phase of taking nootropics, and as better tools and more data come along, the leading thinkers in the space see a powerful future. For example, they are already beginning to look past biochemistry to the epigenome. Not only is the epigenome the code that runs much of your native biochemistry, we now know that experiences in life can be recorded in your epigenome and then passed onto future generations. There is every reason to believe that you are currently running epigenetic code that you inherited from your great-grandmother’s life experiences. And there is every reason to believe that the epigenome can be hacked – that the nootropics of the future can not only support and enhance our biochemistry, but can permanently change the epigenetic code that drives that biochemistry and that we pass onto our children.
When you start taking legit nootropics, you get to leave all of that behind you.  You may never achieve perfect concentration (most of us never will), but you should find you are able to concentrate on the task at hand for much longer than you do now.  You will end up taking fewer breaks, and you might start finishing up your work on time each day again—or even early!
Sun: This is a day I devote to spiritual disciplines and deep personal exploration, along with a hefty dose of neurogenesis, and for a day such as this, I’ll use a more potent neuron sprouting and ego-dissolving mix – most notably a blend of psilocybin microdose with Lion’s Mane extract and niacin (if the skin flush and increased blood flow from niacin tends to be too much for you, you can also use “nicotinamide riboside”, a form of vitamin B3 that has similar effects without the flushing).

When taken regularly, Vitacern Brain Focus Supplement can help your mind function at its best for noticeable improvements in brain power. Our brain supplement promotes better concentration and improved focus to help you excel at work or school. In addition, our focus supplement aids in brain health throughout life for clearer thinking and memory support.

Absorption of nicotine across biological membranes depends on pH. Nicotine is a weak base with a pKa of 8.0 (Fowler, 1954). In its ionized state, such as in acidic environments, nicotine does not rapidly cross membranes…About 80 to 90% of inhaled nicotine is absorbed during smoking as assessed using C14-nicotine (Armitage et al., 1975). The efficacy of absorption of nicotine from environmental smoke in nonsmoking women has been measured to be 60 to 80% (Iwase et al., 1991)…The various formulations of nicotine replacement therapy (NRT), such as nicotine gum, transdermal patch, nasal spray, inhaler, sublingual tablets, and lozenges, are buffered to alkaline pH to facilitate the absorption of nicotine through cell membranes. Absorption of nicotine from all NRTs is slower and the increase in nicotine blood levels more gradual than from smoking (Table 1). This slow increase in blood and especially brain levels results in low abuse liability of NRTs (Henningfield and Keenan, 1993; West et al., 2000). Only nasal spray provides a rapid delivery of nicotine that is closer to the rate of nicotine delivery achieved with smoking (Sutherland et al., 1992; Gourlay and Benowitz, 1997; Guthrie et al., 1999). The absolute dose of nicotine absorbed systemically from nicotine gum is much less than the nicotine content of the gum, in part, because considerable nicotine is swallowed with subsequent first-pass metabolism (Benowitz et al., 1987). Some nicotine is also retained in chewed gum. A portion of the nicotine dose is swallowed and subjected to first-pass metabolism when using other NRTs, inhaler, sublingual tablets, nasal spray, and lozenges (Johansson et al., 1991; Bergstrom et al., 1995; Lunell et al., 1996; Molander and Lunell, 2001; Choi et al., 2003). Bioavailability for these products with absorption mainly through the mucosa of the oral cavity and a considerable swallowed portion is about 50 to 80% (Table 1)…Nicotine is poorly absorbed from the stomach because it is protonated (ionized) in the acidic gastric fluid, but is well absorbed in the small intestine, which has a more alkaline pH and a large surface area. Following the administration of nicotine capsules or nicotine in solution, peak concentrations are reached in about 1 h (Benowitz et al., 1991; Zins et al., 1997; Dempsey et al., 2004). The oral bioavailability of nicotine is about 20 to 45% (Benowitz et al., 1991; Compton et al., 1997; Zins et al., 1997). Oral bioavailability is incomplete because of the hepatic first-pass metabolism. Also the bioavailability after colonic (enema) administration of nicotine (examined as a potential therapy for ulcerative colitis) is low, around 15 to 25%, presumably due to hepatic first-pass metabolism (Zins et al., 1997). Cotinine is much more polar than nicotine, is metabolized more slowly, and undergoes little, if any, first-pass metabolism after oral dosing (Benowitz et al., 1983b; De Schepper et al., 1987; Zevin et al., 1997).
A key ingredient of Noehr’s chemical “stack” is a stronger racetam called Phenylpiracetam. He adds a handful of other compounds considered to be mild cognitive enhancers. One supplement, L-theanine, a natural constituent in green tea, is claimed to neutralise the jittery side-effects of caffeine. Another supplement, choline, is said to be important for experiencing the full effects of racetams. Each nootropic is distinct and there can be a lot of variation in effect from person to person, says Lawler. Users semi-annonymously compare stacks and get advice from forums on sites such as Reddit. Noehr, who buys his powder in bulk and makes his own capsules, has been tweaking chemicals and quantities for about five years accumulating more than two dozens of jars of substances along the way. He says he meticulously researches anything he tries, buys only from trusted suppliers and even blind-tests the effects (he gets his fiancée to hand him either a real or inactive capsule).
Most of the most solid fish oil results seem to meliorate the effects of age; in my 20s, I’m not sure they are worth the cost. But I would probably resume fish oil in my 30s or 40s when aging really becomes a concern. So the experiment at most will result in discontinuing for a decade. At $X a year, that’s a net present value of sum $ map (\n -> 70 / (1 + 0.05)^n) [1..10] = $540.5.
If you want to try a nootropic in supplement form, check the label to weed out products you may be allergic to and vet the company as best you can by scouring its website and research basis, and talking to other customers, Kerl recommends. "Find one that isn't just giving you some temporary mental boost or some quick fix – that’s not what a nootropic is intended to do," Cyr says.
Mosconi uses a pragmatic approach to improve your diet for brain health. The book is divided in three parts. The first one provides information regarding the brain nutritional requirement. The second one teaches you how to eat better. And, the third part tests you to find out where you are in terms of feeding yourself well. This includes an 80 question test that grades you as either Beginner/Intermediate/Advanced. “Beginner” entails you have little food awareness. You eat a lot of processed food. “Advanced” entails you eat very healthily, mainly organic foods. And, “Intermediate” falls in between.
On the plus side: - I noticed the less-fatigue thing to a greater extent, getting out of my classes much less tired than usual. (Caveat: my sleep schedule recently changed for the saner, so it’s possible that’s responsible. I think it’s more the piracetam+choline, though.) - One thing I wasn’t expecting was a decrease in my appetite - nobody had mentioned that in their reports.I don’t like being bothered by my appetite (I know how to eat fine without it reminding me), so I count this as a plus. - Fidgeting was reduced further
Caffeine metabolism is primarily determined by the cytochrome enzyme P-450 1A2 (CYP1A2), and studies have shown that different ethnic populations exhibit widely varying expressions of the gene responsible for CYP1A2. Evidence suggests that a particular CYP1A2 impacts caffeine consumption by modifying the risks of certain diseases that are associated with caffeine consumption. It has also been shown that variations in the expression of genes that code for adenosine and dopamine receptors play a role in mediating your response to caffeine. For example, in Caucasians, the presence of certain genetic expressions for both adenosine and dopamine receptors is associated with caffeine-induced anxiety. Variations in CYP1A2 are also responsible for the speed at which different people metabolize caffeine.
From the standpoint of absorption, the drinking of tobacco juice and the interaction of the infusion or concoction with the small intestine is a highly effective method of gastrointestinal nicotine administration. The epithelial area of the intestines is incomparably larger than the mucosa of the upper tract including the stomach, and the small intestine represents the area with the greatest capacity for absorption (Levine 1983:81-83). As practiced by most of the sixty-four tribes documented here, intoxicated states are achieved by drinking tobacco juice through the mouth and/or nose…The large intestine, although functionally little equipped for absorption, nevertheless absorbs nicotine that may have passed through the small intestine.
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.

The desire to improve cognitive functioning has probably existed since the dawn of human consciousness. Throughout our evolution, increased mental agility has been associated with fitness and improved odds of survival and success. Although concoctions to stimulate brainpower have existed in Chinese and Indian medicine for hundreds of years, Western nootropics were not developed until 1964.

The desire to improve cognitive functioning has probably existed since the dawn of human consciousness. Throughout our evolution, increased mental agility has been associated with fitness and improved odds of survival and success. Although concoctions to stimulate brainpower have existed in Chinese and Indian medicine for hundreds of years, Western nootropics were not developed until 1964.


Another factor to consider is whether the nootropic is natural or synthetic. Natural nootropics generally have effects which are a bit more subtle, while synthetic nootropics can have more pronounced effects. It’s also important to note that there are natural and synthetic nootropics. Some natural nootropics include Ginkgo biloba and ginseng. One benefit to using natural nootropics is they boost brain function and support brain health. They do this by increasing blood flow and oxygen delivery to the arteries and veins in the brain.
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The brain’s preferred fuel is glucose, which comes most readily from carbs. Without ample glucose, you may struggle with brain fog and difficulty focusing. While you want to avoid refined carbs, whole grains contain fiber and help keep your blood sugar on an even keel. (Sharp rises and falls in blood sugar can impair your cells’ ability to uptake glucose because of insulin resistance, explains Malik.)
That is, perhaps light of the right wavelength can indeed save the brain some energy by making it easier to generate ATP. Would 15 minutes of LLLT create enough ATP to make any meaningful difference, which could possibly cause the claimed benefits? The problem here is like that of the famous blood-glucose theory of willpower - while the brain does indeed use up more glucose while active, high activity uses up very small quantities of glucose/energy which doesn’t seem like enough to justify a mental mechanism like weak willpower.↩
Surgeries – Here's another unpleasant surprise. You're probably thinking we're referring to a brain surgery, but that's not the only surgery that can influence the blood flow to your brain the bad way. For example, a heart surgery can cause hypoperfusion. How? Fat globules, which are released during these kinds of procedures, can find their way to your brain and disrupt the optimal blood flow.
The basic idea is to remedy a deficiency (not look for acute stimulant effects) and magnesium has a slow excretion rate18, so week-long blocks seem appropriate. I can reuse the same methodology as the lithium self-experiment. The response variables will be the usual mood/productivity self-rating and, since I was originally interested in magnesium for possible sleep quality improvements, a standardized score of sleep latency + # of awakenings + time spent awake (the same variable as my potassium sleep experiment).
Increase your memory, alertness, energy and focus with the most revolutionary “limitless” pill ever created. As we age, our brains start to slow down both in reaction time and in the recalling of memories. That’s why we need to not only regain our mental capacity, we need to enhance it to such heights that we go well beyond where we started. When you use the dietary supplement Addium, you can total replenish and revitalize your mental alertness in a safe, all-natural way. Made of some of the most powerful brain enhancing ingredients on the market, Addium can be used each day to increase memory function, enhance brain power, increase physical energy and stay sharper and more focused. Don’t just settle for feeling like everyone else; it’s time to take your mind to a limitless state of mental preparedness. Addium Brain Enhancing Dietary Supplement also contains the following benefits: • Boosts your capacity for learning • Increases your alertness and focus • Safe and all natural • Promotes strong brain function • Enhances memory and performance Addium contains: Vitamin B6 - An economical source for cardio health and energy metabolism. Addium contains a Proprietary Blend of: Acetyl L-Carnitine - Energizes the mind and promotes concentration. L-Theanine - Enhances endocrine function, stimulating some brain waves and leaving others unaffected. Caffeine - Increase mental alertness. Rhodiola Rosea Extract - Fights the physical and mental effects of stress. Bacopa Monnieri Extract – This ingredient increases cerebral blood flow and cognitive function at the same time.
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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