Does FDA consider diseases resulting from essential nutrient deficiencies (e.g., scurvy, pellagra) to be diseases for which a medical food could be labeled and marketed?

No. Diseases (e.g., scurvy, pellagra) that result from essential nutrient deficiencies
(e.g., deficiencies of vitamin C, niacin) are primarily caused by inadequate intake
(e.g., famine, significant calorie restriction, eating disorders, alcoholism, diet
practices/fad diets). The deficiencies, excluding any permanent physical damage, can
typically be corrected once foods with these essential nutrients (or dietary
supplements, if necessary) are made available and/or consumed. Because such
diseases can typically be managed through consumption of a healthy, well-balanced
diet, FDA generally would not consider a product labeled and marketed for these
diseases to meet the statutory and regulatory criteria for a medical food (see 21 CFR
101.9(j)(8)(ii)).