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IA #66-74, 10/17/07, IMPORT ALERT #66-74, "DETENTION WITHOUT PHYSICAL
EXAMINATION OF DENTIFRICE PRODUCTS CONTAINING DIETHYLENE GLYCOL (DEG)",
Attachment 11/05/07


This revision updates the product codes.  Changes are denoted by asterisks
(***).

TYPE OF ALERT: Detention Without Physical Examination (DWPE)

               NOTE:  This import alert contains the Agency's current
               guidance to FDA field personnel regarding the
               manufacturer(s) and/or product(s) at issue. It does not
               create or confer any rights for or on any person and it does
               not operate to bind FDA or the public.

PRODUCT:       All dentifrice products, including aerosols, liquids,
               toothpastes, and tooth powders with or without fluoride
               containing DEG

               See attachment for specific product and manufacturers

PRODUCT
CODE:               53I[][]01 Toothpaste without Fluoride
               *** 63R[][][][] *** Toothpaste with Fluoride
               76N[][]XZ Kit, Dental Hygiene
               *** 68Y[][][][] *** Animal drugs, N.E.C.

PROBLEM:       Unapproved and adulterated drugs; adulterated and/or
               misbranded cosmetics; contains DEG

PAF:           AAP (for toothpaste with fluoride and dental kits containing
               toothpaste with fluoride)

               FAD (for toothpaste without fluoride and dental kits
               containing toothpaste without fluoride)

COUNTRIES:          See attachment

MANUFACTURER/
SHIPPER:       See attachment

CHARGES:       For fluoride containing dentifrice drug products:

               "The article is subject to refusal of admission pursuant to
               Section 801(a)(3) in that it appears to be a new drug within
               the meaning of Section 201(p) without an effective new drug
               application (NDA) [Unapproved New Drug, Section 505(a)]."
               CHARGE CODE: UNAPPROVED

                               and

               "The article is subject to refusal of admission pursuant to
               Section 801(a)(3) in that it appears that the methods used
               in, or the facilities or controls used for, its manufacture,
               processing, packing, or holding do not conform to or are not
               operated or administered in conformity with current good
               manufacturing practice to assure that such drug meets the
               requirements of this Act as to safety and has the identity
               and strength, and meets the quality and purity
               characteristics, which it purports or is represented to
               possess [Adulterated Drugs, Section 501(a)(2)(B)]."
               CHARGE CODE: DRUG GMPS

               For non-fluoride containing dentifrice cosmetic products:

               "The article is subject to refusal of admission pursuant to
               section 801(a)(3) in that it appears to be adulterated in
               that it contains a poisonous or deleterious substance,
               namely diethylene glycol, which may render it injurious to
               users under such conditions of use as are customary or usual
               [Adulterated Cosmetic, Section 601(a)]."
               CHARGE CODE: POISONOUS

RECOMMENDING
OFFICE:        CDER, OC, Division of New Drugs and Labeling Compliance
               (HFD-310) and CFSAN, Office of Cosmetic and Colors, HFS-608

REASON FOR
ALERT:         Diethylene glycol (DEG) is a glycol compound possessing
               toxicity similar to ethylene glycol. It is a Central Nervous
               System depressant and potent kidney and liver toxin when
               ingested. It is commonly used in industry as a solvent, a
               thickening agent, a humectant, and as a component in
               antifreeze and gas conditioning formulations.

               DEG has been improperly used as a low-cost substitute for
               glycerin and propylene glycol in pharmaceutical preparations
               resulting in various lethal poisoning incidents in humans
               worldwide. Among these incidents are, elixir sulfanilamide
               in the U.S., sedative mixtures in South Africa, paracetamol
               elixirs in Bangladesh and Nigeria, acetaminophen syrup in
               Haiti, and a cough expectorant product in India. Most
               recently, a cough syrup resulted in serious man injury and
               over 40 deaths in Panama in September 2006. These recent DEG
               poisoning incidents involved a "glycerin" product
               manufactured in China that was a mixture of sorbitol and DEG
               and less than one percent glycerin.

               In May 2007, FDA received accounts that toothpaste from
               China shipped to Panama, Australia, and the Dominican
               Republic was found to contain DEG.  A significant amount of
               toothpaste from China is imported into the United States.
               FDA is presently sampling dentifrice products manufactured
               in China to determine potential contamination with DEG.

               To date, FDA has found DEG in three products manufactured by
               Goldcredit International Trading, China. The products are
               Cooldent Fluoride, Cooldent Spearmint, and Cooldent ICE.
               Analysis of these products has revealed that they contain
               between 3 and 4 percent diethylene glycol. FDA has also
               found DEG in one product manufactured by Suzhou City Jinmao
               Daily Chemicals Co., China.  Analysis of that product, Shir
               Fresh Mint Fluoride Paste, found that it contained
               approximately 1% DEG.  These products have been included in
               the DPWE list attachment of this alert.  As the agency
               identifies other toothpaste products containing DEG, these
               products and their manufacturers will also be added to the
               Import Alert.

               The products were labeled as containing diglycol.  Diglycol
               is one of many synonyms of diethylene glycol.  According to
               REPROTEXT   System, diethylene glycol may be also known as:

               1.   Brecolane ndg
               2.   Carbitol
               3.   Deactivator E
               4.   Deactivator H
               5.   DEG
               6.   Degrees
               7.   Dicol
               8.   Diethylene ether
               9.   Diethylene glycol
               10.  Diethylenglykol (Czech)
               11.  Digenos
               12.  Diglycol
               13.  Digol
               14.  Dihydroxydiethyl ether
               15.  2,2'-Dihydroxydiethyl ether
               16.  beta,beta'-Dihydroxydiethyl ether
               17.  Dihydroxyethylether
               18.  2,2'-Dihydroxyethyl ether
               19.  Dissolvant APV
               20.  Ethanol, 2,2'-oxybis-
               21.  Ethanol, 2,2'-oxydi-
               22.  Ethylene diglycol
               23.  Glycol ether
               24.  Glycol ethyl ether
               25.  2-Hydroxyethyl ether
               26.  bis(2-Hydroxyethyl)ether
               27.  3-Oxapentane-1,5-diol
               28.  3-Oxa-1,5-pentanediol
               29.  2,2'-Oxybisethanol
               30.  2,2'-Oxybis-ethanol
               31.  2,2'-Oxydiethanol
               32.  2,2'-Oxyethanol
               33.  TL4N

               FDA has also identified a number of other dentifrice
               products manufactured by Goldcredit that are labeled as
               containing DEG (or a synonym thereof).  These products have
               also been included in the DWPE list on this alert.

               Dentifrice products may be marketed in the United States as
               drugs or cosmetics.  Dentifrice products intended to prevent
               or mitigate dental cavities/decay (anticaries toothpaste)
               are regulated as over the counter (OTC) drugs.  OTC
               anticaries toothpaste containing diethylene glycol cannot be
               marketed in the U.S. without an approved new drug
               application (NDA).  DEG can be toxic and even fatal in
               humans and FDA is not aware of DEG having been used for a
               material extent and time in formulating OTC anticaries drug
               products.  Thus, FDA regards any OTC anticaries drug product
               containing DEG to be a "new drug" as defined by section
               201(p) of the Federal Food, Drug, and Cosmetic Act (the
               Act).  "New drugs" must be the subject of an approved NDA
               under section 505 of the Act to be legally marketed in the
               United States . Presently, there are no OTC anticaries drug
               products containing DEG approved for marketing in the U.S.

               The use of DEG in OTC anticaries drug products causes them
               to be adulterated under section 501(a)(2)(B) of the Act
               because of the toxicity of DEG when ingested, and therefore,
               the methods or controls used to manufacture the anticaries
               drug containing the DEG do not conform to current Good
               Manufacturing Practices to assure the drug meets the
               requirements of the Act regarding safety.

               Non-fluoride dentifrices products that are not drugs are
               ordinarily marketed as cosmetics, as their intended use is
               for oral hygienic cleansing.

               At this time, the only DEG-containing dentifrice products
               identified by FDA as being offered for import into the U.S.
               are from China.  However, no DEG-containing dentifrice
               products manufactured in China or any other country may be
               imported into the U.S.  Therefore, this alert covers
               dentifrice products containing DEG from any source.

GUIDANCE:      Districts may detain without physical examination all
               shipments of dentifrice products listed in the attachment.

               Districts may detain without physical examination any
               shipment of dentifrice products labeled as containing
               diethyleneglycol or any of its synonyms.

               Districts may detain without physical examination all
               shipments of dental hygiene kits which contain dentifrice
               products listed in the attachment or which contain
               dentifrice products labeled as containing diethylene glycol
               or any of its synonyms.

               For questions regarding dentifrice product marketed as drugs
               please contact CDER Import-Export Team at 301-827-8967.

               For questions regarding dentifrice product marketed as
               cosmetics please contact, Richard Jewell, CFSAN, Labeling
               Compliance Team, at 301-436-2596 or
               Richard.jewell@fda.hhs.gov

PRIORITIZATION
GUIDANCE:           I

FOI:                No purging required

KEYWORDS:      Toothpaste, mouthwash, dentifrice, DEG

PREPARED BY:   Ada Irizarry /CDER/OC/DNLC, 301-827-8967
               Richard Jewell, CFSAN, HFS-608, 301-436-2596
               Ted Poplawski, DIOP, 301-443-6553

DATE LOADED
INTO FIARS:         October 17, 2007
            ATTACHMENT TO IMPORT ALERT #66-74 11/05/07

"LIST OF DENTIFRICES PRODUCTS MANUFACTURED THAT CONTAINS DIETHYLENE GLYCOL
(DEG) AND/OR ARE LABELED AS CONTAINING DIETHYLENE GLYCOL"

                            CHINA (CN)

Manufacturer                                 Products

1. Goldcredit International Enterprises LTD       CooldentFluoride
666 Shuguang BeiRd                           Cooldent Spearmint
Hangitown                                         Cooldent ICE
Yangzhou, China                                   Dr Cool Toothpaste
FEI# 3005396179                                   Everfresh Toohpaste
                                             Superdent Toothpaste
                                             5/31/07
Other addresses:
Goldcredit International Enterprises, LTD
9 F Wuxi National Ind. Design District
Liyuan Economic Dev Zone
Wuxi Chin , China
FEI# 3005043484
     3005446962

Goldcredit International Enterprises, LTD
#151 Lakebank Elegant Gardenwest
Jincheng Road
Wuxi, Jiangsu, China 214123
FEI# 3005775027
     3005854733

2. Gold Credit International Trading Co LTD       Clean Rite Toothpaste
17th fl Changquing Bldg.                          Clean Rite Toothpaste
6 Jie Fang North Rd                               Kit
Wuxi 214005                                  Oralmax Extreme Action
Jiangsu, China                                    Kit
FEI# 3005535612                                   Oralmax Extreme Action 3
     3005566861                                   Pack Kit
     3005970990                                   Oral Bright Fresh
     3003883350                                   Spearmint Flavor
                                             Bright Max Peppermint
                                             Flavor
                                             5/31/07
Other addresses:
Gold Credit International Trading Co LTD
20 Floor Unit G Wah KwongBldg. 333
Zhongsnan Rd , Wuxi 214001
Jiangsu , China
FEI# 3003754241

3. Suzhou City Jinmao Daily Chemicals Co. Ltd.         Shir Fresh Mint
Jingeng Village Huangqiao Town                    Fluoride Paste
Xiangcheng Dist. Suzhou Jiangsu China             5/31/07
Suzhou City, China
FEI# 3005225258

4. Shanghai Light Industrial                      Freshh Spearmint Type
Products Imp & Exp Corp. Ltd.                     Toothpaste
16th-18th Floor Hong Yun Building                 6/13/07
501 Wu Ning Road
Shanghai, China 200063
FEI# 3001110041




5. Suzhou Qing Xin Daily                          All Toothpaste
Chemical Co., Ltd.                           6/20/07
(AKA)Yen Chu Heng Uun Daily
Chemical Products
158 Jinggiang Rd., New Development
Suzhou, China
FEI# 3006296210

6. Guangdong Well-known Ceramics   Co., Ltd.      Tian Qi Toothpaste
Ceramics Building                                 6/20/07
No. 268 Huanshi Rd. Central
Guangzhan, China
FEI# 3004058513

Other Address:
Guangdong Well-known Ceramics Co., Ltd.
Rm.917-920, No.316 Huanshi Road Central,
Guangzhou, China
FEI# 3005451313

Jiangsu Soho Intl. Group Corp                     Flora Fresh
No. 628 Yang ZI Jaing Middle Rd                   Toothpaste
Yangzhouyangzhou 214400                           7/13/07
China
FEI #3006154639

Ningbo Powerwell Fine Chemical                    Healing Care
Industrial Co., Ltd                          Toothpaste in
Gao Qiao Industrial                          Dental Kit
Development Zone                                  7/13/07
Yinzhou District
Ningbo 315047
China
FEI #3004823229


H & L Industrial, Rm 2405 Sunwise Ind.       Amerfresh Toothpaste
Centre16-26 Wang Wo, Tsuen Wan               63R[][]05
China (Mainland)                             9/12/07
FEI# 3005437162

Yangzhou Hengyuan Daily Chemical Co Ltd,          Dentakleen Toothpaste
Hanji town, Yangzhou                         63R[][]06
Jiangsu                                 9/12/07
China (Mainland)
FEI# 3006358035

Global Hotel Necessities Co., Ltd.,          Toothpaste Dental Kits
zhennan Industrial Area,                     53I[][]01
Jiu Jiang Town, Nanhai District              9/12/07
Guangdong
China (Mainland)
FEI# 3004553413

Yongnan Daily Use Chemical Factory      Escents Toothpaste
No 123 Xinyong Road                (may be part of an amenity kit)
Zhongshan, Guangdong Pr                 53I[][]01
China (Mainland)                        76N[][]XZ
FEI # 3006306255                        63R[][][][]
                                   10/09/2007

SHIPPER

Win Dragon Ltd
Rm 1004, Albion Plaza
No 2-6 Granville Road
Kowloon
Hong Kong
FEI # 3004587593

Zhejiang Bohai Import And Export Co.    Crescent Cavity Fighting Toothpaste
302 Room, No. 546, Chouzhou Road        63R[][][][]
Zhejiang                           53I[][]01
China (Mainland)                        10/09/2007
FEI# 3005885035

SHIPPER:

YiWu Saiskai Import & Export Co.
     aka Saiskai Import & Export Co.
No201, Unit 3, Building 42,
Yongsheng District
Yiwu City, Zhejiang
China (Mainland)
FEI # 3006492974

MANUFACTURER
Ajiao Toothbrush Firm                   Crescent Cavity Fighting Toothpaste
H1-0353 Shop, Huan Yuan Market          63R[][][][]
China Commodity City                    53I[][]01
Yiwu City, Zhejiang                10/09/2007
China (Mainland)
FEI # 3006492940

SHIPPER:
YiWu Saiskai Import & Export Co.
     aka Saiskai Import & Export Co.
No201, Unit 3, Building 42,
Yongsheng District
Yiwu City, Zhejiang
China (Mainland)
FEI # 3006492974

Hangzhou Vet & Pet Supplies Co Ltd Pro Dental Mint Flavored Pet Toothpaste
14f No 229 Tiyunchang Road         68Y--99
Hangzhou                      10/9/2007
China (Mainland)
FEI# 3006326248

Yangzhou Royal Home Products            Dentakleen Toothpaste
     Manufacture Co., Ltd.              53I[][]01
922-923, 28# Wanhong City               63[][][][]
Garden, Yangzhou                        11/5/07
Jiangsu
China (Mainland)
FEI# 3006206362