Homeopathic Human Growth Hormone and the Illegal Risks

by Eric L. Foxman, AAHP Secretary, Pharm. (Ret.)


A quick scan of the internet shows that consumers can readily purchase over-the-counter products that allegedly contain homeopathic Human Growth Hormone (HGH).

AAHP wants to remind all manufacturers, repackers, distributors, and marketers that these products are illegal and subject those involved to felony prosecution under the FD&C Act.

Section 331 (e) of the act specifically identifies the distribution of human growth hormone “for any use in humans other than the treatment of a disease or other recognized medical condition, where such use has been authorized by the Secretary of Health and Human Services” as a prohibited act subject to imprisonment and/or fine.

The only “authorization” available is an approved New Drug Application. There is no exemption for homeopathically prepared HGH, or any other criteria based on content, no matter how small. Note the wording of the act: “for any use… unless the use has been authorized.” AAHP is unaware of any such authorization for any homeopathic HGH product. Thus all distribution of homeopathic HGH is illegal.

The FD&C Act states that violations are felonies under the Controlled Substances Act with the attendant potential for forfeiture as a risk to the persons so investigated. The act further directs the Drug Enforcement Agency to investigate potential violations. Speaking as a pharmacist, I can assure readers that any DEA investigation is a rigorous and difficult event to experience; in comparison, an FDA inspection would be a welcome alternative. It is only a matter of time before the DEA turns its attention to this type of marketing.

Read more, including appropriate sections of the law, regarding homeopathic HGH.