Nevertheless, a drug that improved your memory could be said to have made you smarter. We tend to view rote memory, the ability to memorize facts and repeat them, as a dumber kind of intelligence than creativity, strategy, or interpersonal skills. "But it is also true that certain abilities that we view as intelligence turn out to be in fact a very good memory being put to work," Farah says.
Instead, I urge the military to examine the use of smart drugs and the potential benefits they bring to the military. If they are safe, and pride cognitive enhancement to servicemembers, then we should discuss their use in the military. Imagine the potential benefits on the battlefield. They could potentially lead to an increase in the speed and tempo of our individual and collective OODA loop. They could improve our ability to become aware and make observations. Improve the speed of orientation and decision-making. Lastly, smart drugs could improve our ability to act and adapt to rapidly changing situations.
Critics will often highlight ethical issues and the lack of scientific evidence for these drugs. Ethical arguments typically take the form of “tampering with nature.” Alena Buyx discusses this argument in a neuroethics project called Smart Drugs: Ethical Issues. She says that critics typically ask if it is ethically superior to accept what is “given” instead of striving for what is “made”. My response to this is simple. Just because it is natural does not mean it is superior.
Because smart drugs like modafinil, nicotine, and Adderall come with drawbacks, I developed my own line of nootropics, including Forbose and SmartMode, that’s safe, widely available, and doesn’t require a prescription. Forskolin, found in Forbose, has been a part of Indian Ayurvedic medicine for thousands of years. In addition to being fun to say, forskolin increases cyclic adenosine monophosphate (cAMP), a molecule essential to learning and memory formation. [8]
This tendency is exacerbated by general inefficiencies in the nootropics market - they are manufactured for vastly less than they sell for, although the margins aren’t as high as they are in other supplement markets, and not nearly as comical as illegal recreational drugs. (Global Price Fixing: Our Customers are the Enemy (Connor 2001) briefly covers the vitamin cartel that operated for most of the 20th century, forcing food-grade vitamins prices up to well over 100x the manufacturing cost.) For example, the notorious Timothy Ferriss (of The Four-hour Work Week) advises imitators to find a niche market with very high margins which they can insert themselves into as middlemen and reap the profits; one of his first businesses specialized in… nootropics & bodybuilding. Or, when Smart Powders - usually one of the cheapest suppliers - was dumping its piracetam in a fire sale of half-off after the FDA warning, its owner mentioned on forums that the piracetam was still profitable (and that he didn’t really care because selling to bodybuilders was so lucrative); this was because while SP was selling 2kg of piracetam for ~$90, Chinese suppliers were offering piracetam on AliBaba for $30 a kilogram or a third of that in bulk. (Of course, you need to order in quantities like 30kg - this is more or less the only problem the middlemen retailers solve.) It goes without saying that premixed pills or products are even more expensive than the powders.
I started with the 10g of Vitality Enhanced Blend, a sort of tan dust. Used 2 little-spoonfuls (dust tastes a fair bit like green/oolong tea dust) into the tea mug and then some boiling water. A minute of steeping and… bleh. Tastes sort of musty and sour. (I see why people recommended sweetening it with honey.) The effects? While I might’ve been more motivated - I hadn’t had caffeine that day and was a tad under the weather, a feeling which seemed to go away perhaps half an hour after starting - I can’t say I experienced any nausea or very noticeable effects. (At least the flavor is no longer quite so offensive.)
Neuroprime – Mind Nutrition’s offering to the nootropic industry. Mind Nutrition is one of the most interesting nootropics we’ve found on the industry. It brings a formula that is their solution for the market, as a fundamental combination of vitamins and nootropics, or at least they call it. Neuroprime brings that to the table, as well as the fact that Neuroprime is also one of the most transparent companies that we’ve seen. Their online site is detailed, yet clean, without making any outrageous claims or statements. However, we here at Top10BrainPills.com… Learn More...
Somewhat ironically given the stereotypes, while I was in college I dabbled very little in nootropics, sticking to melatonin and tea. Since then I have come to find nootropics useful, and intellectually interesting: they shed light on issues in philosophy of biology & evolution, argue against naive psychological dualism and for materialism, offer cases in point on the history of technology & civilization or recent psychology theories about addiction & willpower, challenge our understanding of the validity of statistics and psychology - where they don’t offer nifty little problems in statistics and economics themselves, and are excellent fodder for the young Quantified Self movement4; modafinil itself demonstrates the little-known fact that sleep has no accepted evolutionary explanation. (The hard drugs also have more ramifications than one might expect: how can one understand the history of Southeast Asia and the Vietnamese War without reference to heroin, or more contemporaneously, how can one understand the lasting appeal of the Taliban in Afghanistan and the unpopularity & corruption of the central government without reference to the Taliban’s frequent anti-drug campaigns or the drug-funded warlords of the Northern Alliance?)

As with any thesis, there are exceptions to this general practice. For example, theanine for dogs is sold under the brand Anxitane is sold at almost a dollar a pill, and apparently a month’s supply costs $50+ vs $13 for human-branded theanine; on the other hand, this thesis predicts downgrading if the market priced pet versions higher than human versions, and that Reddit poster appears to be doing just that with her dog.↩

20 March, 2x 13mg; first time, took around 11:30AM, half-life 3 hours, so halved by 2:30PM. Initial reaction: within 20 minutes, started to feel light-headed, experienced a bit of physical clumsiness while baking bread (dropped things or poured too much thrice); that began to pass in an hour, leaving what felt like a cheerier mood and less anxiety. Seems like it mostly wore off by 6PM. Redosed at 8PM TODO: maybe take a look at the HRV data? looks interestingly like HRV increased thanks to the tianeptine 21 March, 2x17mg; seemed to buffer effects of FBI visit 22 March, 2x 23 March, 2x 24 March, 2x 25 March, 2x 26 March, 2x 27 March, 2x 28 March, 2x 7 April, 2x 8 April, 2x 9 April, 2x 10 April, 2x 11 April, 2x 12 April, 2x 23 April, 2x 24 April, 2x 25 April, 2x 26 April, 2x 27 April, 2x 28 April, 2x 29 April, 2x 7 May, 2x 8 May, 2x 9 May, 2x 10 May, 2x 3 June, 2x 4 June, 2x 5 June, 2x 30 June, 2x 30 July, 1x 31 July, 1x 1 August, 2x 2 August, 2x 3 August, 2x 5 August, 2x 6 August, 2x 8 August, 2x 10 August, 2x 12 August: 2x 14 August: 2x 15 August: 2x 16 August: 1x 18 August: 2x 19 August: 2x 21 August: 2x 23 August: 1x 24 August: 1x 25 August: 1x 26 August: 2x 27 August: 1x 29 August: 2x 30 August: 1x 02 September: 1x 04 September: 1x 07 September: 2x 20 September: 1x 21 September: 2x 24 September: 2x 25 September: 2x 26 September: 2x 28 September: 2x 29 September: 2x 5 October: 2x 6 October: 1x 19 October: 1x 20 October: 1x 27 October: 1x 4 November: 1x 5 November: 1x 8 November: 1x 9 November: 2x 10 November: 1x 11 November: 1x 12 November: 1x 25 November: 1x 26 November: 1x 27 November: 1x 4 December: 2x 27 December: 1x 28 December: 1x 2017 7 January: 1x 8 January: 2x 10 January: 1x 16 January: 1x 17 January: 1x 20 January: 1x 24 January: 1x 25 January: 2x 27 January: 2x 28 January: 2x 1 February: 2x 3 February: 2x 8 February: 1x 16 February: 2x 17 February: 2x 18 February: 1x 22 February: 1x 27 February: 2x 14 March: 1x 15 March: 1x 16 March: 2x 17 March: 2x 18 March: 2x 19 March: 2x 20 March: 2x 21 March: 2x 22 March: 2x 23 March: 1x 24 March: 2x 25 March: 2x 26 March: 2x 27 March: 2x 28 March: 2x 29 March: 2x 30 March: 2x 31 March: 2x 01 April: 2x 02 April: 1x 03 April: 2x 04 April: 2x 05 April: 2x 06 April: 2x 07 April: 2x 08 April: 2x 09 April: 2x 10 April: 2x 11 April: 2x 20 April: 1x 21 April: 1x 22 April: 1x 23 April: 1x 24 April: 1x 25 April: 1x 26 April: 2x 27 April: 2x 28 April: 1x 30 April: 1x 01 May: 2x 02 May: 2x 03 May: 2x 04 May: 2x 05 May: 2x 06 May: 2x 07 May: 2x 08 May: 2x 09 May: 2x 10 May: 2x 11 May: 2x 12 May: 2x 13 May: 2x 14 May: 2x 15 May: 2x 16 May: 2x 17 May: 2x 18 May: 2x 19 May: 2x 20 May: 2x 21 May: 2x 22 May: 2x 23 May: 2x 24 May: 2x 25 May: 2x 26 May: 2x 27 May: 2x 28 May: 2x 29 May: 2x 30 May: 2x 1 June: 2x 2 June: 2x 3 June: 2x 4 June: 2x 5 June: 1x 6 June: 2x 7 June: 2x 8 June: 2x 9 June: 2x 10 June: 2x 11 June: 2x 12 June: 2x 13 June: 2x 14 June: 2x 15 June: 2x 16 June: 2x 17 June: 2x 18 June: 2x 19 June: 2x 20 June: 2x 22 June: 2x 21 June: 2x 02 July: 2x 03 July: 2x 04 July: 2x 05 July: 2x 06 July: 2x 07 July: 2x 08 July: 2x 09 July: 2x 10 July: 2x 11 July: 2x 12 July: 2x 13 July: 2x 14 July: 2x 15 July: 2x 16 July: 2x 17 July: 2x 18 July: 2x 19 July: 2x 20 July: 2x 21 July: 2x 22 July: 2x 23 July: 2x 24 July: 2x 25 July: 2x 26 July: 2x 27 July: 2x 28 July: 2x 29 July: 2x 30 July: 2x 31 July: 2x 01 August: 2x 02 August: 2x 03 August: 2x 04 August: 2x 05 August: 2x 06 August: 2x 07 August: 2x 08 August: 2x 09 August: 2x 10 August: 2x 11 August: 2x 12 August: 2x 13 August: 2x 14 August: 2x 15 August: 2x 16 August: 2x 17 August: 2x 18 August: 2x 19 August: 2x 20 August: 2x 21 August: 2x 22 August: 2x 23 August: 2x 24 August: 2x 25 August: 2x 26 August: 1x 27 August: 2x 28 August: 2x 29 August: 2x 30 August: 2x 31 August: 2x 01 September: 2x 02 September: 2x 03 September: 2x 04 September: 2x 05 September: 2x 06 September: 2x 07 September: 2x 08 September: 2x 09 September: 2x 10 September: 2x 11 September: 2x 12 September: 2x 13 September: 2x 14 September: 2x 15 September: 2x 16 September: 2x 17 September: 2x 18 September: 2x 19 September: 2x 20 September: 2x 21 September: 2x 22 September: 2x 23 September: 2x 24 September: 2x 25 September: 2x 26 September: 2x 27 September: 2x 28 September: 2x 29 September: 2x 30 September: 2x October 01 October: 2x 02 October: 2x 03 October: 2x 04 October: 2x 05 October: 2x 06 October: 2x 07 October: 2x 08 October: 2x 09 October: 2x 10 October: 2x 11 October: 2x 12 October: 2x 13 October: 2x 14 October: 2x 15 October: 2x 16 October: 2x 17 October: 2x 18 October: 2x 20 October: 2x 21 October: 2x 22 October: 2x 23 October: 2x 24 October: 2x 25 October: 2x 26 October: 2x 27 October: 2x 28 October: 2x 29 October: 2x 30 October: 2x 31 October: 2x 01 November: 2x 02 November: 2x 03 November: 2x 04 November: 2x 05 November: 2x 06 November: 2x 07 November: 2x 08 November: 2x 09 November: 2x 10 November: 2x 11 November: 2x 12 November: 2x 13 November: 2x 14 November: 2x 15 November: 2x 16 November: 2x 17 November: 2x 18 November: 2x 19 November: 2x 20 November: 2x 21 November: 2x 22 November: 2x 23 November: 2x 24 November: 2x 25 November: 2x 26 November: 2x 27 November: 2x 28 November: 2x 29 November: 2x 30 November: 2x 01 December: 2x 02 December: 2x 03 December: 2x 04 December: 2x 05 December: 2x 06 December: 2x 07 December: 2x 08 December: 2x 09 December: 2x 10 December: 2x 11 December: 2x 12 December: 2x 13 December: 2x 14 December: 2x 15 December: 2x 16 December: 2x 17 December: 2x 18 December: 2x 19 December: 2x 20 December: 2x 21 December: 2x 22 December: 2x 23 December: 2x 24 December: 2x 25 December: 2x ran out, last day: 25 December 2017 –>


Vinh Ngo, a San Francisco family practice doctor who specializes in hormone therapy, has become familiar with piracetam and other nootropics through a changing patient base. His office is located in the heart of the city’s tech boom and he is increasingly sought out by young, male tech workers who tell him they are interested in cognitive enhancement.
Took pill around 6 PM; I had a very long drive to and from an airport ahead of me, ideal for Adderall. In case it was Adderall, I chewed up the pill - by making it absorb faster, more of the effect would be there when I needed it, during driving, and not lingering in my system past midnight. Was it? I didn’t notice any change in my pulse, I yawned several times on the way back, my conversation was not more voluminous than usual. I did stay up later than usual, but that’s fully explained by walking to get ice cream. All in all, my best guess was that the pill was placebo, and I feel fairly confident but not hugely confident that it was placebo. I’d give it ~70%. And checking the next morning… I was right! Finally.
Taken together, these considerations suggest that the cognitive effects of stimulants for any individual in any task will vary based on dosage and will not easily be predicted on the basis of data from other individuals or other tasks. Optimizing the cognitive effects of a stimulant would therefore require, in effect, a search through a high-dimensional space whose dimensions are dose; individual characteristics such as genetic, personality, and ability levels; and task characteristics. The mixed results in the current literature may be due to the lack of systematic optimization.

Noopept was developed in Russia in the 90s, and is alleged to improve learning. This drug modifies acetylcholine and AMPA receptors, increasing the levels of these neurotransmitters in the brain. This is believed to account for reports of its efficacy as a 'study drug'. Noopept in the UK is illegal, as the 2016 Psychoactive Substances Act made it an offence to sell this drug in the UK - selling it could even lead to 7 years in prison. To enhance its nootropic effects, some users have been known to snort Noopept.

Since coffee drinking may lead to a worsening of calcium balance in humans, we studied the serial changes of serum calcium, PTH, 1,25-dihydroxyvitamin D (1,25(OH)2D) vitamin D and calcium balance in young and adult rats after daily administration of caffeine for 4 weeks. In the young rats, there was an increase in urinary calcium and endogenous fecal calcium excretion after four days of caffeine administration that persisted for the duration of the experiment. Serum calcium decreased on the fourth day of caffeine administration and then returned to control levels. In contrast, the serum PTH and 1,25(OH)2D remained unchanged initially, but increased after 2 weeks of caffeine administration…In the adult rat group, an increase in the urinary calcium and endogenous fecal calcium excretion and serum levels of PTH was found after caffeine administration. However, the serum 1,25(OH)2D levels and intestinal absorption coefficient of calcium remained the same as in the adult control group.
11:30 AM. By 2:30 PM, my hunger is quite strong and I don’t feel especially focused - it’s difficult to get through the tab-explosion of the morning, although one particularly stupid poster on the DNB ML makes me feel irritated like I might on Adderall. I initially figure the probability at perhaps 60% for Adderall, but when I wake up at 2 AM and am completely unable to get back to sleep, eventually racking up a Zeo score of 73 (compared to the usual 100s), there’s no doubt in my mind (95%) that the pill was Adderall. And it was the last Adderall pill indeed.
And in his followup work, An opportunity cost model of subjective effort and task performance (discussion). Kurzban seems to have successfully refuted the blood-glucose theory, with few dissenters from commenting researchers. The more recent opinion seems to be that the sugar interventions serve more as a reward-signal indicating more effort is a good idea, not refueling the engine of the brain (which would seem to fit well with research on procrastination).↩

Certain pharmaceuticals could also qualify as nootropics. For at least the past 20 years, a lot of people—students, especially—have turned to attention deficit hyperactivity disorder (ADHD) drugs like Ritalin and Adderall for their supposed concentration-strengthening effects. While there’s some evidence that these stimulants can improve focus in people without ADHD, they have also been linked, in both people with and without an ADHD diagnosis, to insomnia, hallucinations, seizures, heart trouble and sudden death, according to a 2012 review of the research in the journal Brain and Behavior. They’re also addictive.

I started with the 10g of Vitality Enhanced Blend, a sort of tan dust. Used 2 little-spoonfuls (dust tastes a fair bit like green/oolong tea dust) into the tea mug and then some boiling water. A minute of steeping and… bleh. Tastes sort of musty and sour. (I see why people recommended sweetening it with honey.) The effects? While I might’ve been more motivated - I hadn’t had caffeine that day and was a tad under the weather, a feeling which seemed to go away perhaps half an hour after starting - I can’t say I experienced any nausea or very noticeable effects. (At least the flavor is no longer quite so offensive.)


But he has also seen patients whose propensity for self-experimentation to improve cognition got out of hand. One chief executive he treated, Ngo said, developed an unhealthy predilection for albuterol, because he felt the asthma inhaler medicine kept him alert and productive long after others had quit working. Unfortunately, the drug ended up severely imbalancing his electrolytes, which can lead to dehydration, headaches, vision and cardiac problems, muscle contractions and, in extreme cases, seizures.
"A system that will monitor their behavior and send signals out of their body and notify their doctor? You would think that, whether in psychiatry or general medicine, drugs for almost any other condition would be a better place to start than a drug for schizophrenia," says Paul Appelbaum, director of Columbia University's psychiatry department in an interview with the New York Times.
Amphetamines have a long track record as smart drugs, from the workaholic mathematician Paul Erdös, who relied on them to get through 19-hour maths binges, to the writer Graham Greene, who used them to write two books at once. More recently, there are plenty of anecdotal accounts in magazines about their widespread use in certain industries, such as journalism, the arts and finance.
Among the questions to be addressed in the present article are, How widespread is the use of prescription stimulants for cognitive enhancement? Who uses them, for what specific purposes? Given that nonmedical use of these substances is illegal, how are they obtained? Furthermore, do these substances actually enhance cognition? If so, what aspects of cognition do they enhance? Is everyone able to be enhanced, or are some groups of healthy individuals helped by these drugs and others not? The goal of this article is to address these questions by reviewing and synthesizing findings from the existing scientific literature. We begin with a brief overview of the psychopharmacology of the two most commonly used prescription stimulants.
That said, there are plenty of studies out there that point to its benefits. One study, published in the British Journal of Pharmacology, suggests brain function in elderly patients can be greatly improved after regular dosing with Piracetam. Another study, published in the journal Psychopharmacology, found that Piracetam improved memory in most adult volunteers. And another, published in the Journal of Clinical Psychopharmacology, suggests it can help students, especially dyslexic students, improve their nonverbal learning skills, like reading ability and reading comprehension. Basically, researchers know it has an effect, but they don’t know what or how, and pinning it down requires additional research.
MPH was developed more recently and marketed primarily for ADHD, although it is sometimes prescribed off label or used nonmedically to increase alertness, energy, or concentration in conditions other than ADHD. Both MPH and AMP are on the list of substances banned from sports competitions by the World Anti-Doping Agency (Docherty, 2008). Both also have the potential for abuse and dependence, which detracts from their usefulness and is the reason for their classification as Schedule II controlled substances. Although the risk of developing dependence on these drugs is believed to be low for individuals taking them for ADHD, the Schedule II classification indicates that these drugs have a high potential for abuse and that abuse may lead to severe dependence.
CDP-Choline is also known as Citicoline or Cytidine Diphosphocholine. It has been enhanced to allow improved crossing of the blood-brain barrier. Your body converts it to Choline and Cytidine. The second then gets converted to Uridine (which crosses the blood-brain barrier). CDP-Choline is found in meats (liver), eggs (yolk), fish, and vegetables (broccoli, Brussels sprout).
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.
My first impression of ~1g around 12:30PM was that while I do not feel like running around, within an hour I did feel like the brain fog was lighter than before. The effect wasn’t dramatic, so I can’t be very confident. Operationalizing brain fog for an experiment might be hard: it doesn’t necessarily feel like I would do better on dual n-back. I took 2 smaller doses 3 and 6 hours later, to no further effect. Over the following weeks and months, I continued to randomly alternate between potassium & non-potassium days. I noticed no effects other than sleep problems.
White, Becker-Blease, & Grace-Bishop (2006) 2002 Large university undergraduates and graduates (N = 1,025) 16.2% (lifetime) 68.9%: improve attention; 65.2:% partying; 54.3%: improve study habits; 20%: improve grades; 9.1%: reduce hyperactivity 15.5%: 2–3 times per week; 33.9%: 2–3 times per month; 50.6%: 2–3 times per year 58%: easy or somewhat easy to obtain; write-in comments indicated many obtaining stimulants from friends with prescriptions
along with the previous bit of globalization is an important factor: shipping is ridiculously cheap. The most expensive S&H in my modafinil price table is ~$15 (and most are international). To put this in perspective, I remember in the 90s you could easily pay $15 for domestic S&H when you ordered online - but it’s 2013, and the dollar has lost at least half its value, so in real terms, ordering from abroad may be like a quarter of what it used to cost, which makes a big difference to people dipping their toes in and contemplating a small order to try out this ’nootropics thing they’ve heard about.
If you could take a drug to boost your brainpower, would you? This question, faced by Bradley Cooper’s character in the big-budget movie Limitless, is now facing students who are frantically revising for exams. Although they are nowhere near the strength of the drug shown in the film, mind-enhancing drugs are already on the pharmacy shelves, and many people are finding the promise of sharper thinking through chemistry highly seductive.
"A system that will monitor their behavior and send signals out of their body and notify their doctor? You would think that, whether in psychiatry or general medicine, drugs for almost any other condition would be a better place to start than a drug for schizophrenia," says Paul Appelbaum, director of Columbia University's psychiatry department in an interview with the New York Times.
When Giurgea coined the word nootropic (combining the Greek words for mind and bending) in the 1970s, he was focused on a drug he had synthesized called piracetam. Although it is approved in many countries, it isn’t categorized as a prescription drug in the United States. That means it can be purchased online, along with a number of newer formulations in the same drug family (including aniracetam, phenylpiracetam, and oxiracetam). Some studies have shown beneficial effects, including one in the 1990s that indicated possible improvement in the hippocampal membranes in Alzheimer’s patients. But long-term studies haven’t yet borne out the hype.
Barbaresi WJ, Katusic SK, Colligan RC, Weaver AL, Jacobsen SJ. Modifiers of long-term school outcomes for children with attention-deficit/hyperactivity disorder: Does treatment with stimulant medication make a difference? Results from a population-based study. Journal of Developmental and Behavioral Pediatrics. 2007;28:274–287. doi: 10.1097/DBP.0b013e3180cabc28. [PubMed] [CrossRef]

Given the size of the literature just reviewed, it is surprising that so many basic questions remain open. Although d-AMP and MPH appear to enhance retention of recently learned information and, in at least some individuals, also enhance working memory and cognitive control, there remains great uncertainty regarding the size and robustness of these effects and their dependence on dosage, individual differences, and specifics of the task.
“The author’s story alone is a remarkable account of not just survival, but transcendence of a near-death experience. Cavin went on to become an advocate for survival and survivors of traumatic brain injuries, discovering along the way the key role played by nutrition. But this book is not just for injury survivors. It is for anyone who wants to live (and eat) well.”
Cytisine is not known as a stimulant and I’m not addicted to nicotine, so why give it a try? Nicotine is one of the more effective stimulants available, and it’s odd how few nicotine analogues or nicotinic agonists there are available; nicotine has a few flaws like short half-life and increasing blood pressure, so I would be interested in a replacement. The nicotine metabolite cotinine, in the human studies available, looks intriguing and potentially better, but I have been unable to find a source for it. One of the few relevant drugs which I can obtain is cytisine, from Ceretropic, at 2x1.5mg doses. There are not many anecdotal reports on cytisine, but at least a few suggest somewhat comparable effects with nicotine, so I gave it a try.
"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]
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