Protocols for approval as a "drug" have never been satisfied. In terms of its known actions, G.H.3 can be regarded as either a vitaminic compound or a nutrient. PABA and DEAE are both B-vitamins. Evidence brought forth indicates that both elements are actually nutrients. PABA stimulates the production of several vitamins in the intestines. DEAE is a precursor to choline, which is a B-vitamin complex. Both elements thus form links in developmental chains resulting in these basic building blocks of the body. Therefore, they can be considered nutrients. (14). The Merck index lists G.H.3 as Vitamin H3.