Medical foods are exempt from the labeling requirements for nutrient content claims under the Nutrition Labeling and Education Act of 1990 (see 21 U.S.C. 343(r)(5)(A)). As with any food, a medical food that bears a false or misleading claim would be considered misbranded under section 403(a)(1) of the Federal Food, Drug, and Cosmetic Act (FD&C Act).
