November 26, 2025 By: Asa Waldstein

Homeopathic Product Disease Claims

Takeaway -

Measles claims attract scrutiny

Homeopathic products continue to be targeted by FDA. In this group of five warning letters FDA reinforced their position that homeopathics are drugs and must follow drug rules, including FDA approval.

From warning letter. “(the products) are labeled as homeopathic drugs. Under section 201(g)(1) of the FD&C Act, 21 U.S.C. 321(g)(1), the term “drug” includes articles recognized in the official Homeopathic Pharmacopeia of the United States (HPUS), or any supplement to it. Homeopathic drug products are subject to the same statutory requirements as other drugs; nothing in the FD&C Act exempts homeopathic drugs from any of the requirements related to adulteration, misbranding, or FDA approval.”

A common thread in these letters are claims about measles prevention and support. FDA takes these types of claims seriously as they want to avoid consumers foregoing conventional treatment for potentially unproven therapy. FDA has issued numerous homeopathic-related warning letters over the past few years and they primarily focus on serious disease claims or potentially dangerous products such as opthalimic (eye) products. Check out some of my previous WLW posts on these topics. 

Some of the companies in these warning letters are distributors. FDA has cited product distributors like Amazon and Walmart in the past but recently they’ve also focused on smaller distributors. This reinforces the lesson that all companies are responsible for the products they distribute, especially if they handle the product.

Here is the Homeopathic Drug Products: Guidance. This guidance, together with the warning letter comments, offers insight into FDA’s current thinking on homeopathic enforcement priorities and its use of “enforcement discretion.”

Read the five warning letters here:

Distacart Inc.

VarunKart Group LLC dba Organic Wellnesses

Swift Digital Group LLC dba Swadesii

Handelnine Global, LLC dba Navafresh

Mahita LLC dba PushMyCart

Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.

Written by

Asa Waldstein
Asa Waldstein
Asa Waldstein is a 24-year veteran of the dietary supplement industry, with experience spanning manufacturing, marketing, and regulatory compliance. He is the principal of Apex Compliance, a software company dedicated to streamlining regulatory marketing compliance for the dietary supplement and natural products sectors. Asa also leads Supplement Advisory Group, a boutique consultancy focused on marketing risk analysis, labeling, and practical compliance strategies for websites and social media. Asa has helped oversee three FDA GMP inspections with no 483s and was honored with the 2023 AHPA Herbal Hero Award and the 2024 What's Up Supps Policy and Change Agent Award. He currently serves as Chair of the American Herbal Products Association’s (AHPA) Technology & AI Innovation Committee.