AMP Citrate BANNED in 2015 – FDA Lays the DMBA Hammer Down

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UPDATE 2015: The FDA has BANNED AMP CITRATE! They have sent 13 Warning Letters to companies selling DMBA / AMP Citrate:

See the FDA ‘ban’ letters below.

If you’re tuned into new supplements, you may have seen a relatively new ingredient named AMP citrate added to several fat burners and pre-workout supplements.

This new stimulant has been nicknamed as the “lite” version of its predecessor, and is quickly making waves in the nutrition industry. We keep this post updated with as much information as possible.

The 2015 Ban / FDA Warning Letters

On April 24, 2015, the FDA sent warning letters to thirteen manufacturers of AMP Citrate products. They can be seen below:

• 1ViZN LLC (Enriched Nutrition – Velocity) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444390.htm
• Beta Labs (Oxyphen XR Amp’d) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444381.htm
• Blackstone Labs (Angel Dust) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444383.htm
• Brand New Energy (Yellow Bullet AMP) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444412.htm
• Core Nutritionals (AMP Citrate) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444395.htm
• DSEO LLC (Hybrid Nutrition – HybriLean and PREAMP) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444406.htm
• Genomyx (EVOL) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444378.htm
• Iron Forged Nutrition (Contraband) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444374.htm
• Lecheek Nutrition (AMPilean and AMPitropin) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444567.htm
• Nutrex Research (Adipodex) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444414.htm
• Powder City (AMP Citrate) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444410.htm
• Prime Nutrition (PWO/STIM) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444386.htm
• RPM Nutrition (Red Rum SS) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444398.htm
• VPX Sports (Redline White Heat) – https://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm444377.htm

The quick explanation behind these warning letters is that even if AMP Citrate was natural, the FDA is arguing that the ingredient was never used in the food supply before 1994, nor was a New Dietary Ingredient (NDI) ever filed for it.

So by the law of the land, it’s not legal — until someone proves it was in the food supply prior to 94 or gets the paperwork done (which is unlikely to be approved at this point).

The FDA is also claiming dispute with the synthetically manufactured nature of this ingredient.

We’ll continue to update this post as we learn more information and will see which products are still in violation over time as companies reformulate. In the meantime, here’s our original write-up on DMBA:

A quick disclaimer

There’s still not much concrete information available about this ingredient, and much of the data presented here is anecdotal. f you’re very conservative and need loads of research behind everything you ingest, this one is not going to be for you.

But if you’re looking for a new stimulant and want to see what we’ve discovered so far, then read on, check out the products that have it, and leave some comments.

So what is AMP Citrate?

Also known scientifically as “4-amino-2-methylpentane” (hence the AMP) and sometimes referred to as an herbal extract from “pouchong” or “Chinese white tea,” AMP citrate is a psychostimulatory compound that’s remarkably similar in structure to the now-infamous stimulant that was in Jack3d that Patrick Arnold originally brought back to the market. This comes as no surprise when you look at another scientific name for AMP: 1,3-dimethylbutylamine, or DMBA.

Commercially-available AMP is going to be synthetic, but note that this is not anything new – your vitamin C tablets are extremely likely to be synthetic as well.

What does AMP do for you?

Extrapolating from its older and slightly better-known sibling, AMP is purported to increase blood pressure and bloodflow^[1] along with helping focus, mood, and athletic performance — although the latter is somewhat dubious given the opposite behavior of related compounds. Similar stimulants’ long half-life of roughly 8 hours^[2] can likely be extended to its newer brother, as well, making AMP hard-hitting and long-lasting.

All of this analysis is contingent on AMP behaving similarly to them, of course, which is where we again run into the big problem: AMP on its own just isn’t very well-researched yet. User experiences confirm similar but milder effects, but this is anecdote, not data.

Nonetheless, going by the countless accounts of great workouts with fantastic energy and mood benefits, it’s pretty clear that AMP does deliver on its promises for many. This is not surprising – this is essentially what many aliphatic amines do (an aliphatic amine is one which has no aromatic ring attached to the nitrogen^[3], and often make for nice stimulant effect).

AMP Citrate Dosage: How much should I be taking?

As explained by Natural Micron, an industrial producer of supplements and extracts, AMP comes in two popular forms:

1. AMP Citrate, the most common, has a subtly sweet, lemonade-like taste, and is roughly 35% “active” by molecular mass. It goes best in powdered supplements that will be tasted.
2. DMBA HCl, also gaining some prominence, has a more bitter, chemical taste, but is more than twice as potent as its tastier counterpart at 74% “active” by mass. It’s ideally suited for volume-limited applications like capsules.

If you’re willing to jump into the world of exploratory stimulants, most users have anecdotally reported effectiveness in doses of 200-400mg of the citrate form, which is consistent with what many emerging products are using in their formulations.

This would correspond to a little under half of the HCl form, or roughly 95-190mg for DMBA HCl in a pill or tablet.

It’s true for all stimulants, but especially for under-researched ones: you should always start with low dosages, particularly when combined with other ingredients, and individual tolerance should be carefully and progressively assessed. Those with existing medical conditions should be particularly careful, and it’s always recommended to consult with your doctor.

Is AMP safe? What are the downsides or side effects?

UPDATE: It’s been shown that this product does NOT contain AMP Citrate!^[3] So what’s in it?!?!

The lack of research done on this chemical makes it impossible to authoritatively say that it’s safe.

Although several shorter-term studies on similar stimulants found no evidence of negative health implications in otherwise healthy individuals^[4][5], the lack of long-term safety data along with some reports of it being linked to adverse effects that included heart attacks led regulatory agencies, including the FDA, to ban the substance in dietary and nutritional supplements^[6].

Given that the bulk of our understanding at this time is that “AMP is a lot like its predecessor stim,” similar consideration should be given: if the FDA prohibition worries you, you may want to avoid AMP until more data exists.

Outside the vagaries of the available safety information, a very typical set of stimulant side effects is associated with too much AMP or overall combined stimulant use: jitters, nervousness, anxiety, cardiovascular issues, and a low-energy “crash” are all possibilities for misuse.

In comparing with its predecessor, many users have reported that the effects of AMP are somewhat less pronounced and less “harsh,” but similar in establishing rapid tolerance for regular stimulant consumers. Cross-tolerance with other compounds, resensitization, and the potential for physiological withdrawal are all not yet fully explored.

Was its predecessor ever proven to be truly un-safe for healthy athletes?

Another note on the safety bit: many believe that the other stim was never truly proven to be unsafe, especially when used properly and in low dosages by healthy individuals. The same may go for DMBA here.

Billions of servings of AMP’s predecessor stim were safely sold, but the irresponsibility of a few ruined it for everyone else. As with everything, we caution you to start with low dosages, do not use it if you have any pre-existing medical conditions, and to never use more than the label states.

Point is, this one is likely going to end up the same as the previous one did, and after that, another one will arrive in its place. We urge you to follow the warnings above – this is likely a great-feeling stimulant for healthy athletes, but should not be used by those without a clean bill of health.

Errata: False AMP Citrate?

Oddly enough, the first product to claim to have pure AMP Citrate / DMBA was Genomyx’s AMP Citrate, however, recent research has shown that there is ZERO DMBA inside.^[3]

Which leads us to wonder… what was in there, Genomyx?

(Nootropics are cognitive “brain-enhancers”)

Just how natural is this stuff?

According to two Chinese research studies, which have to be translated to English, and neither study has been confirmed to American standards.

One study (by Chen and Ou) claims to have found DMBA at a miniscule 0.012 ppm in Pouchung tea — as a degradant when storing it!^[7]

The other study was analyzing essential oils from a flower named Coreopsis tinctoria, and claims to have found it as well – but there was no standard used to confirm its finding.^[8]

The point is, even if it is found in nature, these are such small amounts that it’d take 1000kg of Pouchong tea to just get 12mg of DMBA!^[3] This means that anything you’re buying is definitely synthetically-produced.

The USA Today Article

Meanwhile, Alison Young at the USA Today has penned a piece exploring the lack of research. She quotes Pieter Cohen, the author of the research cited above^[3], saying,

“We want the FDA and we want the stores to immediately remove these products from store shelves” — Pieter Cohen, Harvard Medical School^[9]

(Alison the same writer who exposed the criminal Driven Sports founder, Matt Cahill, in her excellently-done hatchet job)

The FDA is aware, action is likely coming

In the USA Today article, the FDA made the following statement:

[The FDA] “is aware of concerns regarding DMBA/AMP Citrate and will consider taking regulatory action, as appropriate, to protect consumers.”^[9]

Besides the Cohen team, two senators and a supplement industry group are also urging the FDA to take regulatory action.^[10,11]

The FDA’s Catch-22

There have been no NDIs filed with the FDA for this ingredient (NDI = New Dietary Ingredient), and if it wasn’t marketed or sold before 1994, an NDI must be filed, according to DSHEA.^[12]

However, since no NDI has been filed, it’s postulated that the FDA can’t fully / legally / easily regulate it as a supplement, since it’s technically not on their books!

VPX Sports Disagrees, claims DSHEA Compliance and incredibility / media-whoring by Dr. Pieter Cohen

Update, October 17, 2014: VPX Sports has just published a blog post defending AMP and how it is DSHEA compliant due to it’s longtime availability in Pouchong Tea. He goes on to call out Dr. Cohen’s credibility (or lack thereof), and attacks him for media-whoring. It’s an incredibly well-written piece and is a must read!^[13]

The wonderfully-written post is written by VPX’s CEO, Jack Owoc

In conclusion – AMP is a naturally occurring constituent contained in the most consumed beverage on planet Earth which is tea. AMP is proven to be found in the Pouchung Tea by the extensive testing as previously described. AMP has been consumed in the food supply by humans for thousands of years and is 100% DSHEA compliant and legal.

–- Jack Owoc, VPX Sports CEO^[13]

It gets better, though:

Cohen babbles scientifically unsound absurdities that are grossly lacking in coherence and cohesion. Further, Cohen’s statements are libelous, slanderous, disingenuous, and damaging.

So I ask, “Cohen — Who removed atoms from a chemical structure?” Other than trying to deceive the public at large and the fact that you know nothing about chemistry, what are you trying to accomplish here with your outrageous gibberish and balderdash?

All VPX products mentioned clearly state: “WARNING: NOT BY USE FOR INDIVIDUALS UNDER THE AGE OF 18.” IN ALL BOLD CAPS PROMINENTLY ON THE LABEL. Therefore, I ask –who is selling to adolescents? You have neither the qualifications nor the right to publically mouth off and disparage the most university gold standard studied product line in the history of the dietary supplement industry!

-– Jack Owoc, VPX Sports CEO^[13]

The whole thing is pure gold:

Cohen who and/or what gives you the authority and audacity to habitually tell the FDA what they should and should not be doing? — Jack Owoc, VPX Sports CEO^[13]

It goes on and on. Just go and read the archived article yourself,^[13] because every paragraph is quoteworthy!

GNC and Vitamin Shoppe Remove all AMP Citrate Products

Most interesting after the USA Today article is that GNC and Vitamin Shoppe have removed all products containing these ingredients from their shelves and websites!^[14]

GNC declined to comment, stating that they do not typically comment on product selection or availability.

AMP Citrate makes its return in 2015

As mentioned in the top of the post, much of the fuss over a single article came and went, and the FDA performed no actions on AMP Citrate. From what we can see, nobody had issues with it when used properly.

Because of this lack of action, and the fact that users quite like it, the ingredient is on its way back to products, mostly from the smaller, more aggressive and quicker companies.

What about Drug Tests? Are these products okay?

This is a tough one to answer as of late 2014. Right now, the ingredient is so new, it’s not currently outright banned by any organization. With the recommendations from NSF International in the Cohen research^[6], we expect that to change very soon. It will likely be banned sooner than later.

In the past with similar stims, less-sensitive drug tests that aren’t as specific may cause problems, and a higher-quality re-test would show that you were clean… but since AMP Citrate is similarly structured, you may find yourself in the same boat.

There is good news, though: 4-Amino-2-Methylpentane Citrate has one less carbon atom, so it’s a bit more differentiated. This might make it less likely to cause false positives, but we cannot gaurantee anything.

As always, if you are a drug-tested athlete, you must check every single ingredient with your governing body, and cross-reference every ingredient you take with their banned substances list. It’s not always worth risking, and it’s your responsibility — not the supplement manufacturer’s, and definitely not ours.