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Syntech(SSPF) International,Inc. TO: Division of Stzndardsand Labeling Regulations Office of Nutritional Products,Labeling, and Dietary Supplement(HFS-820) Center for l3od Safetyand Applied Nutrition Food and Drug Administration 5100 Paint Branch Parkway CollegeFQtk,MD 20740 SUPPLEMENTTO Premarket Notification for a New Dietary Ingredient: Betaphrine Prernarket Notification of a New Dietary Ingredient: Betaphrine Submitted by: rs> .I /lhs?x?/w&/f #8:.iw/ 7-7-t/eP~S~OicnlT SyntechSSPFInternational,Inc. 310 Paseo Tesoro Walnut, CA 91789 Tel: 909.444.588 1O/8/04 Syntech (SSPF) International, Inc. SUPPLEMENTTO Premarket Notification for a New Dietary Ingredient: Betaphrine QUESTIONS The original notificatron of Betaphrine as a New Dietary ingredient contained the information required within 21 CFR 5190.6 required clarification as evidenced by the inquiry from your office. The specifics of the Inquiries were as follows: I) The nature of the dosage forms and detail of these forms a The categcry of the substance in accordance with Section 201(H) of the FFDCA. Answers Concerning the dosage forms intended for Betaphrine and details of the dosage the following is offered for clarification: j- The material Betaphrine is provided in so/id dosage forms for at-al : consumption. Specificallly, tablets and/or capsules containing Betaphrine are offered as dietary supplements. The quantity of BetaphriI?e _. contairled in a single serving of dietary supplements containing .’ Betaphrine does not exceed 80 mg of Betaphrine. Typical ranges for presentation are between 20 mg to 80 mg per serving. The ,’ recommended consumption of Betaphrine in dietary supplements f3 set _, at a maximum of 80 mg of Betaphrine pt7r day. The category of thr substance in accordance with Section 201(ff) of the FFDCA is as follows: 1, In accordance with the Section ZOl(ff) for the Federa/ Foocl, Drug and J Cosmetic Act (FFDUI), Betaphrine ls a dietary ingredient in that it 13: .i“” ‘X product (other than tobacco) that is intended to supplement the diet . ,I . , ” r Sup,olements containing Eet-aphrine fufiher meet the statutory I in that they contain: definitYon Premarket Notification of a New Dietary Ingredient: 10/8/04 Betaphrine a dietary substance 16/- use by man to supplement the diet by increasing the total daify intake, or concentrate, metabolite, constitueni; extract or combination of these ingredients. ” 1t I , , Thrs information is submitted as requested in duplicate and forwarded to your offices via overnight delivery. Should there be any further questions concerning this notification, please do not hesitate to contact us. Respectfully submitted, $U7Me] /ihfs-b$ k? , ZhL4 PW @TW”LJ~Wt Syntech (SSPF) International, Syntech (SSPF) International, Inc. Inc. -----___ .__--______ 2