********************************************************************************************** ROCHE CHEMICAL DIVISION Hoffman-La Roche Inc Nutley, New Jersey 07110 - (201) 235 5000 September 11, 1986 Dear Customer: As a customer for Roche Canthaxanthin sold under various trademarks, such as Roxanthin Red 10 WS, Roxanthin Red 10 Beadlets and Dry Canthaxanthin 10% SD, we would like to review with you the status of this carotenoid. Canthaxanthin is cleared under FDA regulations as a color for general food use up to a maximum of 30 mg. per pound or pint of food; but, of course, it may not be used in foods covered by standards of identity unless allowed by the standards. It may also be used to color drug products in amounts consistent with good manufacturing practices. At this time, these are the only uses allowed under FDA regulations for this substance in the United States in humans. The applicable regulations are 21CFR 73.75, as to foods, and 21CFR 73.1075, as to drugs. Presently, Canthaxanthin is not approved by the Food and Drug Administration for use in ingested products intended to color the human body, i.e., oral-tanning products. Until the FDA gives its approval, FDA considers such products to be illegal in the United States. Tanning products have been seized under provisions of the Federal Food, Drug and Cosmetic Act; further, attempts to import these tanning products have resulted in their being detained at the ports of entry. In view of the foregoing. it has been, and continues to be, our company policy not to sell Canthaxanthin for oral-tanning preparations in the United States. If you are not already aware of the fact, you should know that in investigations originally carried out in Canada, and more recently in Germany, a number of people who had been taking Canthaxanthin tanning preparations at high levels, for prolonged periods of time exhibited as a side effect a so far unexplained phenomenon which the authors describe as glistening, apparently crystalline deposits in the inner layer of the retina of the eye, in particular, around the the macula. In some of the subjects investigated, sensitive ophthalmological tests revealed, slowing down of light-darkness adaptation of the eye, though the clinical significance of this remains to be fully determined. This functional disturbance is reported to regress on discontinuation of the Canthaxanthin tanning preparation. The deposits in the retina, however, have not been observed to regress, but remain in place without apparent impairment of vision, perception of color or field of vision. Canthaxanthin is one of the more than 400 naturally-occurring and identified carotenoid colors which have been present in food for thousands of years. For many years Canthaxanthin has been, and presently continues to be, used as a safe food colorant in the United States - mainly to give a red color in foods where the natural color has been lost during processing. In the oral-tanning application referred to above, which had been allowed by a number of foreign countries (but has since been banned with few exceptions) users frequently ingested 100 milligrams or more a day for prolonged periods, which clearly distinguishes it from the low levels encountered in food. We appreciate your continued interest in non-certifiable Roche carotenoids for food, dietary supplement, and drug coloring applications. If you have any ques- tions regarding Roche carotenoids, please do not hesitate to contact us. Cordially, William R. Driscoll Director of Technical Services Human Health and Nutrition Department Roche Vitamins and Fine Chemicals