I don’t believe there’s any need to control for training with repeated within-subject sampling, since there will be as many samples on both control and active days drawn from the later trained period as with the initial untrained period. But yes, my D5B scores seem to have plateaued pretty much and only very slowly increase; you can look at the stats file yourself.
A big part is that we are finally starting to apply complex systems science to psycho-neuro-pharmacology and a nootropic approach. The neural system is awesomely complex and old-fashioned reductionist science has a really hard time with complexity. Big companies spends hundreds of millions of dollars trying to separate the effects of just a single molecule from placebo – and nootropics invariably show up as “stacks” of many different ingredients (ours, Qualia , currently has 42 separate synergistic nootropics ingredients from alpha GPC to bacopa monnieri and L-theanine). That kind of complex, multi pathway input requires a different methodology to understand well that goes beyond simply what’s put in capsules.
The evidence? Although everyone can benefit from dietary sources of essential fatty acids, supplementation is especially recommended for people with heart disease. A small study published in 2013 found that DHA may enhance memory and reaction time in healthy young adults. However, a more recent review suggested that there is not enough evidence of any effect from omega 3 supplementation in the general population.
In the study, which evaluated the eating habits and mental ability of more than 950 older adults for an average of five years, those adults who ate a serving of leafy green veggies once or twice a day experienced slower mental deterioration than those who ate no vegetables, even when factors like age, education and family history of dementia were factored in.
Gibson and Green (2002), talking about a possible link between glucose and cognition, wrote that research in the area …is based on the assumption that, since glucose is the major source of fuel for the brain, alterations in plasma levels of glucose will result in alterations in brain levels of glucose, and thus neuronal function. However, the strength of this notion lies in its common-sense plausibility, not in scientific evidence… (p. 185).
Alex's sense of who uses stimulants for so-called "non-medical" purposes is borne out by two dozen or so scientific studies. In 2005 a team led by Sean Esteban McCabe, a professor at the University of Michigan, reported that in the previous year 4.1% of American undergraduates had taken prescription stimulants for off-label use - at one school the figure was 25%, while a 2002 study at a small college found that more than 35% of the students had used prescription stimulants non-medically in the previous year.
[…] The verdict is out on brain health and aging. Scientists now know that memory loss and cognitive decline are not an inevitable part of growing older. In fact, the research proves quite the contrary. You can keep your mind sharp well into old age with a strategy that combines a healthy, active lifestyle with a brain-protecting diet and brain-boosting supplements. […]
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.
Manually mixing powders is too annoying, and pre-mixed pills are expensive in bulk. So if I’m not actively experimenting with something, and not yet rich, the best thing is to make my own pills, and if I’m making my own pills, I might as well make a custom formulation using the ones I’ve found personally effective. And since making pills is tedious, I want to not have to do it again for years. 3 years seems like a good interval - 1095 days. Since one is often busy and mayn’t take that day’s pills (there are enough ingredients it has to be multiple pills), it’s safe to round it down to a nice even 1000 days. What sort of hypothetical stack could I make? What do the prices come out to be, and what might we omit in the interests of protecting our pocketbook?
The Nootroo arrives in a shiny gold envelope with the words “proprietary blend” and “intended for use only in neuroscience research” written on the tin. It has been designed, says Matzner, for “hours of enhanced learning and memory”. The capsules contain either Phenylpiracetam or Noopept (a peptide with similar effects and similarly uncategorised) and are distinguished by real flakes of either edible silver or gold. They are to be alternated between daily, allowing about two weeks for the full effect to be felt. Also in the capsules are L-Theanine, a form of choline, and a types of caffeine which it is claimed has longer lasting effects.
That first night, I had severe trouble sleeping, falling asleep in 30 minutes rather than my usual 19.6±11.9, waking up 12 times (5.9±3.4), and spending ~90 minutes awake (18.1±16.2), and naturally I felt unrested the next day; I initially assumed it was because I had left a fan on (moving air keeps me awake) but the new potassium is also a possible culprit. When I asked, Kevin said:
Gibson and Green (2002), talking about a possible link between glucose and cognition, wrote that research in the area …is based on the assumption that, since glucose is the major source of fuel for the brain, alterations in plasma levels of glucose will result in alterations in brain levels of glucose, and thus neuronal function. However, the strength of this notion lies in its common-sense plausibility, not in scientific evidence… (p. 185).
Alpha GPC + AC-11 + Bacopa Monniera + Huperzine: This combination is found in the supplement Alpha Brain, created by the company Onnit. According to a clinical trial that was conducted by the Boston Center for Memory, this combination has demonstrated a notable increase in cognitive performance for healthy individuals and shows particular potential to boost the memory and learning capacity of users. AC-11 is derived from a rainforest herb, and studies have found that it may be able to help people in a variety of ways such as slowing the growth of cancer due to its DNA repairing antioxidant properties. This stack seems to work best if you take it daily for at about two weeks. After that, effects become more pronounced over time, so, similar to the Gingko, Bacopa, Lion’s Mane stack above you need to allow this blend to build up in your system before you judge its overall effectiveness.

To make things more interesting, I think I would like to try randomizing different dosages as well: 12mg, 24mg, and 36mg (1-3 pills); on 5 May 2014, because I wanted to finish up the experiment earlier, I decided to add 2 larger doses of 48 & 60mg (4-5 pills) as options. Then I can include the previous pilot study as 10mg doses, and regress over dose amount.


Nootropic (new-tro-pik) is the term for supplements, also known as smart drugs, that improve brain function. They can be food substances like phenethylamine and L-Theanine, found in chocolate and green tea, respectively. Nootropics also include extracted and purified components of medicinal plants, as well as substances synthesized from chemical precursors, such as piracetam, the world's first official nootropic (piracetam was created in 1964 in Belgium by a team of scientists whose leader, Dr. Corneliu E. Giurgea, coined the term). Since then piracetam has been widely used as a cognitive enhancer and to treat neurological diseases like Alzheimer's.
Flaxseed oil is, ounce for ounce, about as expensive as fish oil, and also must be refrigerated and goes bad within months anyway. Flax seeds on the other hand, do not go bad within months, and cost dollars per pound. Various resources I found online estimated that the ALA component of human-edible flaxseed to be around 20% So Amazon’s 6lbs for $14 is ~1.2lbs of ALA, compared to 16fl-oz of fish oil weighing ~1lb and costing ~$17, while also keeping better and being a calorically useful part of my diet. The flaxseeds can be ground in an ordinary food processor or coffee grinder. It’s not a hugely impressive cost-savings, but I think it’s worth trying when I run out of fish oil.
We all wish success came in a pill form. That was the premise of the hour and half Adderall commercial/ thriller film ‘Limitless’ starring Bradley Cooper. In the film he popped a transparent round pill and instantly his brain power skyrocketed- anything became possible. Most of us wished that pill existed- and now it does. Donepezil is a drug that is used to treat Alzheimers, but it’s effects on normal people make Adderall and Vyvanse look like a cup of coffee.
Bacopa is a supplement herb often used for memory or stress adaptation. Its chronic effects reportedly take many weeks to manifest, with no important acute effects. Out of curiosity, I bought 2 bottles of Bacognize Bacopa pills and ran a non-randomized non-blinded ABABA quasi-self-experiment from June 2014 to September 2015, measuring effects on my memory performance, sleep, and daily self-ratings of mood/productivity. Because of the very slow onset, small effective sample size, definite temporal trends probably unrelated to Bacopa, and noise in the variables, the results were as expected, ambiguous, and do not strongly support any correlation between Bacopa and memory/sleep/self-rating (+/-/- respectively).
New psychiatric drugs have a way of creating markets for themselves. Disorders often become widely diagnosed after drugs come along that can alter a set of suboptimal behaviours. In this way Ritalin and Adderall helped make ADHD a household name, and advertisements for antidepressants have helped define shyness as a malady. If there's a pill that can clear up the wavering focus of sleep-deprived youth or mitigate the tip-of-the-tongue experience of middle age, then those rather ordinary states may come to be seen as syndromes.
Breathing carefully, I clutched the Costco special edition family size 1.5-liter glass bottle of vodka and carefully extracted 10 milliliters with a miniature glass pipette, which I then transferred into a small amber glass bottle. Then, with my nine-year-old son’s tiny set of school scissors, I snipped exactly 1/10 of LSD from the blotter square I’d ordered from a psychedelic research chemical supplier website the week prior, with a cloaked browser, of course, so the feds didn’t come knocking at my door. I dropped the LSD into the bottle, gave it a thirty-second shake, then placed the bottle in the pantry, next to my protein powder and creatine. I smiled. Within 24 hours, I’d be ready to sample my first homemade, volumetric “microdose” of a drug reported to increase lateral thinking patterns, improve creativity, massively boost productivity and much, much more.
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.
Last winter, I spoke again with Alex, the Harvard graduate, and found that, after a break of several months, he had gone back to taking Adderall - a small dose every day. He felt that he was learning to use the drug in a more "disciplined" manner. Now, he said, it was less about staying up late to finish work he should have done earlier, and more "about staying focused on work, which makes me want to work longer hours". What employer would object to that?

A new all-in-one nootropic mix/company run by some people active on /r/nootropics; they offered me a month’s supply for free to try & review for them. At ~$100 a month (it depends on how many months one buys), it is not cheap (John Backus estimates one could buy the raw ingredients for $25/month) but it provides convenience & is aimed at people uninterested in spending a great deal of time reviewing research papers & anecdotes or capping their own pills (ie. people with lives) and it’s unlikely I could spare the money to subscribe if TruBrain worked well for me - but certainly there was no harm in trying it out.

Blueberries. "Brainberries" is what Steven Pratt, MD, author of Superfoods Rx: Fourteen Foods Proven to Change Your Life, calls these tasty fruits. Pratt, who is also on staff at Scripps Memorial Hospital in La Jolla, Calif., says that in animal studies researchers have found that blueberries help protect the brain from oxidative stress and may reduce the effects of age-related conditions such as Alzheimer's disease or dementia. Studies have also shown that diets rich in blueberries significantly improved both the learning capacity and motor skills of aging rats, making them mentally equivalent to much younger rats. Ann Kulze, MD, author of Dr. Ann's 10-Step Diet: A Simple Plan for Permanent Weight Loss & Lifelong Vitality, recommends adding at least 1 cup of blueberries a day in any form -- fresh, frozen, or freeze-dried.
We’d want 53 pairs, but Fitzgerald 2012’s experimental design called for 32 weeks of supplementation for a single pair of before-after tests - so that’d be 1664 weeks or ~54 months or ~4.5 years! We can try to adjust it downwards with shorter blocks allowing more frequent testing; but problematically, iodine is stored in the thyroid and can apparently linger elsewhere - many of the cited studies used intramuscular injections of iodized oil (as opposed to iodized salt or kelp supplements) because this ensured an adequate supply for months or years with no further compliance by the subjects. If the effects are that long-lasting, it may be worthless to try shorter blocks than ~32 weeks.

All health content on bbcgoodfood.com is provided for general information only, and should not be treated as a substitute for the medical advice of your own doctor or any other health care professional. If you have any concerns about your general health, you should contact  your local health care provider. See our website terms and conditions for more information.

My predictions were substantially better than random chance7, so my default belief - that Adderall does affect me and (mostly) for the better - is borne out. I usually sleep very well and 3 separate incidents of horrible sleep in a few weeks seems rather unlikely (though I didn’t keep track of dates carefully enough to link the Zeo data with the Adderall data). Between the price and the sleep disturbances, I don’t think Adderall is personally worthwhile.


Common environmental toxins – pesticides, for example – cause your brain to release glutamate (a neurotransmitter). Your brain needs glutamate to function, but when you create too much of it it becomes toxic and starts killing neurons. Oxaloacetate protects rodents from glutamate-induced brain damage.[17] Of course, we need more research to determine whether or not oxaloacetate has the same effect on humans.

I’ve been actively benefitting from nootropics since 1997, when I was struggling with cognitive performance and ordered almost $1000 worth of smart drugs from Europe (the only place where you could get them at the time). I remember opening the unmarked brown package and wondering whether the pharmaceuticals and natural substances would really enhance my brain.
Take quarter at midnight, another quarter at 2 AM. Night runs reasonably well once I remember to eat a lot of food (I finish a big editing task I had put off for weeks), but the apathy kicks in early around 4 AM so I gave up and watched Scott Pilgrim vs. the World, finishing around 6 AM. I then read until it’s time to go to a big shotgun club function, which occupies the rest of the morning and afternoon; I had nothing to do much of the time and napped very poorly on occasion. By the time we got back at 4 PM, the apathy was completely gone and I started some modafinil research with gusto (interrupted by going to see Puss in Boots). That night: Zeo recorded 8:30 of sleep, gap of about 1:50 in the recording, figure 10:10 total sleep; following night, 8:33; third night, 8:47; fourth, 8:20 (▇▁▁▁).
Walnuts are chock-full of heart-healthy and anti-inflammatory nutrients, and are the only good nut source of alpha linolenic acid (ALA), HuffPost Healthy Living earlier reported. That means they help promote blood flow, which in turn allows for efficient delivery of oxygen to the brain. And research presented at the 2010 International Conference on Alzheimer's found that mice with the disease who were regularly fed walnuts had improved memory, learning and motor skill coordination, according to MyHealthNewsDaily.
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.
Using neuroenhancers, Seltzer said, "is like customising yourself - customising your brain". For some people, he added, it was important to enhance their mood, so they took antidepressants; but for people like him it was more important "to increase mental horsepower". He said: "It's fundamentally a choice you're making about how you want to experience consciousness." Whereas the 1990s had been about "the personalisation of technology", this decade was about the personalisation of the brain - what some enthusiasts have begun to call "mind hacking".
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.

If I stop tonight and do nothing Monday (and I sleep the normal eight hours and do not pay any penalty), then that’ll be 4 out of 5 days on modafinil, each saving 3 or 4 hours. Each day took one pill which cost me $1.20, but each pill saved let’s call it 3.5 hours; if I value my time at minimum wage, or 7.25/hr (federal minimum wage), then that 3.5 hours is worth $25.37, which is much more than $1.20, ~21x more.
Since the discovery of the effect of nootropics on memory and focus, the number of products on the market has increased exponentially. The ingredients used in a supplement can tell you about the effectiveness of the product. Brain enhancement pills that produce the greatest benefit are formulated with natural vitamins and substances, rather than caffeine and synthetic ingredients. In addition to better results, natural supplements are less likely to produce side effects, compared with drugs formulated with chemical ingredients.
Pyritinol: Pyritinol has anti-oxidant effects for supporting the long-term health of the brain. But its primary benefit is aiding glucose uptake for periods of extended mental strain. If you are studying or working for a long period of time, your brain will start to diminish its glucose (sugar) stores which are the primary way that the brain derives its energy.
The AC-11 that Marcus mentioned for health is an extract from the Amazon jungle vine una de gato, and has been shown in laboratory and clinical trials to encourage DNA repair. The Mucuna pruriens he named for motivation is a legume that's a concentrated source of L-Dopa, which the body converts to the neurotransmitter dopamine. The Huperzia serrata Marcus selected for hunting is the same substance that induces lucid dreaming. This seems appropriate. While I felt the Alpha Brain helped my hunting, maybe I was dreaming. Or maybe a dream state of mind is good for hunting.
Pre and Post-Natal Depression are both complex conditions that can have multifactorial underlying drivers, including genetic and environmental influences. These are currently poorly investigated and the gold standard of treatment is often medication to help stabilise mood. Whilst SSRIs and other types of antidepressants have proven to be helpful for many, they do not address potential causes or drivers of poor mental health and can often mask symptoms. Antidepressants are also not regularly recommended during pregnancy, which is why being more mindful of nutrition and lifestyle habits can be a safer option for you and your baby. There are some natural, evidence-based steps you can take to help support optimal mental wellbeing:
These brain enhancers allow users to go without sleep for extended periods of time. But in the long-term, insomnia is a hazardous side effect, not a so-called benefit. Lack of sleep is extremely detrimental to your brain health and function. It’s during sleep that your brain consolidates memories, cleans away toxins, repairs itself, and creates new brain cells. (52, 53, 54, 55)
As a result of her years of research in this area, Dr. Lisa proposes a variety of foods that lead to better cognitive functioning and those which, in contrast, minimize cognitive functioning. "The best four foods one can consume to boost brain power are fish, dark leafy green veggies, berries, and water," she explains. And the worst? "Fast food, processed foods and poor quality meat." 
Nootropics can also show signs of neuro-preservation and neuro-protection. These compounds directly affect the levels of brain chemicals associated with slowing down the aging process. Some nootropics could in an increase in the production of Nerve Growth Factor and Brain-Derived Neurotrophic Factor to stimulate the growth of neurons and neurites while slowing down the rate of damage as well.
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:

3 days later, I’m fairly miserable (slept poorly, had a hair-raising incident, and a big project was not received as well as I had hoped), so well before dinner (and after a nap) I brew up 2 wooden-spoons of Malaysia Green (olive-color dust). I drank it down; tasted slightly better than the first. I was feeling better after the nap, and the kratom didn’t seem to change that.

QUALITY : They use pure and high quality Ingredients and are the ONLY ones we found that had a comprehensive formula including the top 5 most proven ingredients: DHA Omega 3, Huperzine A, Phosphatidylserine, Bacopin and N-Acetyl L-Tyrosine. Thrive Natural’s Super Brain Renew is fortified with just the right ingredients to help your body fully digest the active ingredients. No other brand came close to their comprehensive formula of 39 proven ingredients. The “essential 5” are the most important elements to help improve your memory, concentration, focus, energy and mental clarity. But, what also makes them stand out above all the rest was that they have several supporting vitamins and nutrients to help optimize brain and memory function. A critical factor for us is that this company does not use fillers, binders or synthetics in their product. We love the fact that their capsules are vegetarian, which is a nice bonus for health conscience consumers.
[…] The 7 Best Brain Boosting Supplements | Live in the Now … – Act now to protect your brain with exercise, a healthy diet and brain boosting supplements! Share the knowledge! … cells and coffee and tomato sauce as my antioxidants since they are cheap out here. organic fruits and veges are also cheap out here to fruits for 3$ can take me 7days! […]
the larger size of the community enables economies of scale and increases the peak sophistication possible. In a small nootropics community, there is likely to be no one knowledgeable about statistics/experimentation/biochemistry/neuroscience/whatever-you-need-for-a-particular-discussion, and the available funds increase: consider /r/Nootropics’s testing program, which is doable only because it’s a large lucrative community to sell to so the sellers are willing to donate funds for independent lab tests/Certificates of Analysis (COAs) to be done. If there were 1000 readers rather than 23,295, how could this ever happen short of one of those 1000 readers being very altruistic?

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:


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)
It doesn't take a neuroscientist with a degree in nutrition to get that diet can affect the brain. It does take a neuroscientist with a degree in nutrition to provide such a smart research-driven analysis of how and to what extent. Brain Food is based on the work of literally hundreds of scientists and provides a dietary roadmap to enhanced cognitive power. That Dr. Mosconi's book is also fully accessible to a layperson makes this a true must read. (Bonus: Chapter 16 is a mini-cookbook with "brain boosting" recipes including several that are kid-friendly.)
But what does this all have to do with food? Our gut helps keep our body’s immune responses and inflammation under control. Additionally, gut hormones that enter the brain or are produced in the brain influence cognitive ability, like understanding and processing new information, staying focused on the task at hand and recognizing when we’re full. (3)
A new all-in-one nootropic mix/company run by some people active on /r/nootropics; they offered me a month’s supply for free to try & review for them. At ~$100 a month (it depends on how many months one buys), it is not cheap (John Backus estimates one could buy the raw ingredients for $25/month) but it provides convenience & is aimed at people uninterested in spending a great deal of time reviewing research papers & anecdotes or capping their own pills (ie. people with lives) and it’s unlikely I could spare the money to subscribe if TruBrain worked well for me - but certainly there was no harm in trying it out.
Low level laser therapy (LLLT) is a curious treatment based on the application of a few minutes of weak light in specific near-infrared wavelengths (the name is a bit of a misnomer as LEDs seem to be employed more these days, due to the laser aspect being unnecessary and LEDs much cheaper). Unlike most kinds of light therapy, it doesn’t seem to have anything to do with circadian rhythms or zeitgebers. Proponents claim efficacy in treating physical injuries, back pain, and numerous other ailments, recently extending it to case studies of mental issues like brain fog. (It’s applied to injured parts; for the brain, it’s typically applied to points on the skull like F3 or F4.) And LLLT is, naturally, completely safe without any side effects or risk of injury.
Googling, you sometimes see correlational studies like Intake of Flavonoid-Rich Wine, Tea, and Chocolate by Elderly Men and Women Is Associated with Better Cognitive Test Performance; in this one, the correlated performance increase from eating chocolate was generally fairly modest (say, <10%), and the maximum effects were at 10g/day of what was probably milk chocolate, which generally has 10-40% chocolate liquor in it, suggesting any experiment use 1-4g. More interesting is the blind RCT experiment Consumption of cocoa flavanols results in acute improvements in mood and cognitive performance during sustained mental effort11, which found improvements at ~1g; the most dramatic improvement of the 4 tasks (on the Threes correct) saw a difference of 2 to 6 at the end of the hour of testing, while several of the other tests converged by the end or saw the controls winning (Sevens correct). Crews et al 2008 found no cognitive benefit, and an fMRI experiment found the change in brain oxygen levels it wanted but no improvement to reaction times.

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]
×