IA #63-01, 5/1/97 - REVISED IMPORT ALERT #63-01, "DETENTION WITHOUT
PHYSICAL EXAMINATION OF COLGATE FLUORIDE TOOTHPASTE FROM
CANADA AND MEXICO AND GUIDANCE FOR ALL OTHER FLUORIDE
TOOTHPASTE PRODUCTS"
NOTE: This revision places Colgate fluoride toothpaste
products from Canada and Mexico on detention
without physical examination. This revision also
updates the title, format, product code and text.
Changes are identified by asterisks (***).
TYPE OF
ALERT :*** Detention without physical examination - for all
Colgate fluoride toothpaste products from Canada
and Mexico.
Guidance - for all other fluoride toothpaste
products.
(Note: This import alert contains guidance to FDA
field personnel only. It does not establish any
requirements, or create any rights for, or
obligations on FDA or regulated entities.) ***
PRODUCT :*** Detention without physical examination - Colgate
fluoride toothpaste products from Canada and
Mexico.
Guidance - All other fluoride toothpaste products,
all other countries,various brands including Crest
and Colgate. ***
PRODUCT
CODE :*** 63R ***
PROBLEM : New drug without an approved new drug application
(DRND)
COUNTRY : Detention without physical examination -
Canada (CA, 260), Mexico (MX, 595)
Guidance - All (999)
MANUFACTURER/
SHIPPER : All
CHARGE : "The article is subject to refusal of admission
pursuant to Section 801(a)(3) in that it appears
to be a new drug without an approved new drug
application (NDA) as required by Section 505(a)."
RECOMMENDING
OFFICE : DIOP (HFC-170) and CDER (HFD-310)
REASON FOR
ALERT :*** There is a continuing problem of imported
toothpaste products with more than one fluoride
ingredient or containing fluoride at a level
higher than that allowed in OTC anticaries
toothpastes, or containing other non permitted
ingredients. These products are considered new
drugs without approved new drug applications.
In the past shipments of toothpaste products from
England, Portugal, Italy, India, China, Brazil,
Chile, Mexico and Canada have been detained
because of double fluoride or excessive fluoride
levels.
Recently representatives of the Colgate-Palmolive
Company have presented information indicating that
Colgate fluoride toothpaste manufactured in Canada
and Mexico, for sale in those countries, is being
diverted into the United States. Based on
information provided by the firm, the Canadian
toothpaste contains cyclamates and the Mexican
toothpaste contains two fluoride ingredients.
Neither formulation is acceptable - cyclamates are
not permitted as sweeteners and the final
monograph on fluoride dentifrices (21CFR355) does
not permit combination of two fluoride
ingredients. These products cannot be brought into
compliance by relabeling. In FY96 there were 10
detentions of Colgate toothpaste from Canada, and
12 detentions of Colgate toothpaste from Mexico.
For FY97 (as of 3/25/97) there have been 4
detentions of Colgate toothpaste from Canada, and
6 detentions of Colgate toothpaste from Mexico.
GUIDANCE : *** Districts may detain without physical
examination all shipments of Colgate fluoride
toothpaste products from Canada and Mexico.
***Districts may perform label reviews on entries
of other anticaries toothpaste products. Products
found labeled as containing double fluoride
ingredients or other non-permitted ingredients
should be detained. Districts may sample other
products for fluoride content, color additives,
and sweeteners. Questions concerning analytical
findings should be referred to Robert Eshelman,
HFD-312, *** 301-594-1065.***
Use the following methodology for determination of fluoride
and monofluorophosphate in toothpastes containing both types
of fluorides:
Journal of Chromatography, Vol. 546, pgs. 351-361, Murawski
1991
"Ion Chromatography for Analysis of Household Consumer
Products"
Journal of Chromatography, Vol. 367, pgs. 423-427, Potter et
al. 1986
"Determination of Fluoride and Monofluorophosphates in
toothpastes by Ion Chromatography"
For determination of fluoride in toothpastes containing
sodium fluoride or stannous fluoride:
Laboratory Information Bulletin (LIB) #2742, pgs. 1-6,
Tobias 1983
"Ion Selective Determination of Free Fluoride in
Toothpaste"
*** For questions or issues concerning science, science
policy, sample collection, analysis, preparation, or
analytical methodology, contact the Division of Field
Science at (301)443-3320 or 3007. ***
FOI: No purging required.
KEYWORDS: Toothpaste, double fluoride, Crest, Colgate
PREPARED BY: Doug Randes, DIOP (301)-443-6553.
DATE LOADED
INTO FIARS : May 1, 1997