He said the SC required the FDA to do a review on Implanon to ensure its safety. Once it gets FDA approval, he said, the two-year old TRO will be automatically lifted. He said the FDA is coming up with guidelines in conducting a review and recertification of Implanon and 49 other contraceptives in the country. But the official said the FDA decision may still be questioned before the Office of the President. “The argument posed by FDA is that in issuing Certificate of Product Registration, they are exercising merely regulatory powers and not quasi-judicial powers, as such, administrative due process should not apply.