Pharm'Up 
The U.S. Food and Drug Administration (FDA) has escalated its crackdown on unauthorized medical devices, issuing an official warning letter to Genetrace, a diagnostics firm based in Blaine, Washington. The agency cited the company for marketing an HIV diagnostic self-collection kit to American consumers without the mandatory regulatory clearances.
The Violation: Adulterated and Misbranded Devices
The product at the center of the warning is a Dried Blood Spot (DBS) card self-collection kit. This kit allows users to collect their own blood samples at home and mail them to a laboratory for HIV testing.
According to the FDA’s Center for Biologics Evaluation and Research (CBER), the kit qualifies as a medical device under the Federal Food, Drug, and Cosmetic Act because it is intended for the diagnosis of disease. However, Genetrace failed to secure the necessary:
- Premarket Approval (PMA): A rigorous review process to ensure safety and efficacy.
- Investigational Device Exemption (IDE): Required for devices being used in clinical studies.
Because these legal requirements were bypassed, the FDA has formally classified the kits as “adulterated” and “misbranded.”
Serious Risks to Public Health
The FDA’s primary concern lies in the lack of verified accuracy. Without regulatory oversight, there is no assurance that:
- Sample Stability: The blood sample remains viable during shipping and temperature fluctuations.
- User Accuracy: A layperson can safely and correctly collect a usable specimen.
- Result Reliability: The diagnostic results provided to the consumer are medically sound.
FDA Guidance: “Self-collection raises critical issues… including whether the sample has been properly shipped and if there is adequate stability given the time lapse between collection and testing.”
Enforcement and Next Steps
The warning letter, dated January 8, 2026, serves as a formal notice for Genetrace to immediately cease the illegal distribution of these kits. The company has been given 15 working days to respond with a plan for corrective action. Failure to comply could result in:
- Seizure of existing inventory.
- Civil Money Penalties (fines).
- Legal Injunctions to prevent further business operations.
The FDA reminded consumers that there are already several FDA-approved over-the-counter (OTC) HIV tests available that provide reliable results at home.
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