>One of my former colleagues once made a "drug" where the excipient actually was therapeutically valuable while the listed API was barely better than placebo. Luckily we didn't submit it for approval.
Why should it be illegal? The submission process would be the same. The reason I sail "luckily" was just that it would be complicated.
I believe there are some topical OTC drugs that work this way :-(
Or did you think making unlicensed drugs is illegal? Of course it isn't -- that's what drug development IS. It's not legal to give such a drug to humans without a valid IND that hasn't been rejected by the FDA but formulating, doing in vitro testing and animal in vivo testing is all perfectly legit.
That seems... ridiculously illegal.