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Draft Guidance for Industry: Substantiation for Structure/Function Claims Made in Infant Formula Labels and Labeling

DraftHuman Foods Program09/09/2016

Description

This guidance document describes the type and quality of evidence that the Food and Drug Administration (FDA or we) recommends infant formula manufacturers and distributors have to substantiate claims about effects on the structure or function of the body (“structure/function claims”) made on the label and in other labeling of nonexempt and exempt infant formulas.

Scope & Applicability

Product Classes

3
Infant Formula

The primary product category covered by the guidance; Essential food product that is the sole source of nutrition for many infants.

Exempt Infant Formula

Infant formulas for infants with inborn errors of metabolism or low birth weight

Dietary Supplement

Products containing dietary ingredients intended to supplement the diet; The final product category for which the NDI is intended.

Stakeholders

5
Manufacturer

Entity responsible for submitting NDINs

Distributors

Entities involved in the supply chain of APIs.

Infant Formula Manufacturers

entities responsible for reviewing evidence and substantiating claims

Distributor

Entity responsible for submitting NDINs

Principal Investigator

Responsible for reviewing case report forms

Regulatory Context

Attributes

2
Statistical Power

adequate statistical power and accounting for planned analyses

Competent and Reliable Scientific Evidence

the substantiation standard required for structure/function claims

Related CFR Sections (4)

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  • Bioresearch Monitoring Program/Institutional Review Board (IRB)

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  • Clinical Investigator

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  • Seafood HACCP/CGMP for Foods/Adulterated/Insanitary Conditions

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  • Institutional Review Board (IRB)

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See Also (8)