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Investigational drugs

Why can't a compound with promising research data just be sold once someone believes it works?

Plain English first, then the primary source. Education, not legal advice.

Interpretation

In short: approval is product-specific and evidence-driven. No education, credential, or label substitutes for it.

Plain English

Under 21 U.S.C. 355, a new drug generally cannot be introduced into interstate commerce unless FDA has approved a marketing application demonstrating it is safe and effective for its intended use. This applies regardless of how promising early research looks.

Approval requires substantial evidence from adequate and well-controlled investigations, which is a much higher bar than laboratory data, animal studies, or informal human trials.

Selling an unapproved new drug is a distinct violation from misbranding or adulteration, and it applies even to products that are honestly labeled and accurately described.

Why it matters

  • This is the core reason RUO chemicals cannot legally be marketed or sold as treatments no matter how strong the underlying science looks.

Where the answer becomes fact-specific

The Foundation does not manufacture legal conclusions. These points change the analysis and may require qualified regulatory counsel.

  • Whether a specific compound already has an approved use, an IND in progress, or no regulatory history at all changes what is permitted.

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