A former career FDA lawyer says Santa Claus has broken almost every rule in the agency’s book and violated numerous food, drug and import laws, regulations and standards over the years.

Benjamin England says Saint Nick secured his position on the FDA’s “naughty list” because he allegedly illegally imported millions of dollars worth of merchandise to children in the United States, albeit as gifts.

“They call that smuggling, folks,” England said in his holiday message.

“I feel bad for the guy,” said England. “Nobody wants to poo-poo on (Santa’s) gift-giving and good cheer but he needs to realize that the FDA’s going to come after him at some point.”

England said the jolly old man’s alleged violations center on:

•  Bringing the oft-requested chocolates, candies and makeup into the country without proper FDA inspection or screening.
•  Failure to properly register Santa’s workshops at the North Pole and other gift-making locations with the FDA.
•  With 2.2 billion children in the world receiving at least 1 gift per Christmas, England worries that many of the packages have labels that ignores listing proper ingredients.

“Just because you’ve been doing something a long time without having any FDA detentions or refusals before doesn’t mean you’re doing it right,” said England in reference to Santa Claus’s past history of successful importing.

“I know for a fact that there are no in-house attorneys working for Mr. Clause at the North Pole because lawyers hate the cold,” said England, who runs an import consulting firm.

Sorry. I couldn’t bring myself to ask FDA for comment on this.