This is Our Time

By Karen Howard
I have always believed this industry, as a whole, is united in a belief that the body has an innate ability to heal, given the right supports. Practitioners of natural health and medicine advocate for, and work closely with, their patients to achieve maximum health status. Independent retailers, our front-line educators, work closely with their customers on how to source quality supplements. Trade associations advocate for the integrity of the supply chain to support production and distribution of products that can produce the health outcomes we all seek. As a self-proclaimed tribe, we have thrived and grown, attracted investment from the pharmaceutical world, created the momentum for systemic adaptation of regenerative agriculture, and (thus far) eschewed adoption of synthetic biology. And yet, we are on a precipice. So here is my affirmation to you, to my organization and our members, to the industry at large and to the consumers that count on us:
  • No dabbling in divisive, angry, judgmental labeling is allowed. It will only lead us to circle the wagons and shoot inside. Love thy neighbor, vaccinated or not, even if you cannot find it in your heart to like them.
  • Commit to supporting the entire supply chain, not just the part you represent. Sales are great. Growth is strong. Yet, we are still relatively small in a world owned by mega-companies, so value the contributions from everyone in your operation and up and down the chain. The health coach, naturopath, independent retailer, raw ingredient supplier, and manufacturer are all in this together.
  • Agree to disagree. There is much information and too little critical thinking. If you believe everything you read, you will be in trouble. Do your due diligence before you pass judgement on a person, product, or a company. Deep listening is a practice we could all benefit from.
  • Recommit to purpose. Own the space and the work we do so well. Do not sacrifice mission for profit. Do not cower from adversity. Do unite for the sake of our future and that of our children. We are all they have got.
This is our time. Time to succeed and improve health status. Time to take bold steps and unify our own industry so that we can be that healing force in the world. I only do work that honors the generations that came before me and serves future generations. That means I am sticking to my pledge to change the healthcare paradigm to one rooted in health, not disease, no matter how hard it is. Will you join me?

Read more from Karen on this topic and others in our Trade Secrets column.

3 Priorities for 2022

By Loren Israelsen
Attempting an industry forecast for 2022 is a fool’s errand. That suits me well, so here goes.

Politics.  Obviously 2022 is a big political year with a mid-term election in November and control of the House and Senate at stake. Our hopes for resolution of the hemp/CBD lawful status issue now seems destined for next year. This is really unfortunate, as delay is decay. The hemp/CBD sector is in trouble—trapped between FDA and congressional inaction. Meanwhile, the pharma sector has accelerated efforts to confine the scope of consumer access with what seems FDA’s tacit agreement. My forecast: If we hope to have a consumer hemp/CBD industry, the many, many stakeholders and voices must come to a more united position and at least establish lawful dietary supplement status.

DSHEA 2.0. This is the last time I will use the term “DSHEA 2.0.” What was intended as an effort to strengthen DSHEA has now somehow morphed into “fixing DSHEA.” DSHEA doesn’t need fixing. What is needed is to strengthen an already-strong law to take into account the commercial and communication realities of 2022. Efforts will continue to strengthen DSHEA. We also expect FDA to continue seeking mandatory product listing. The industry remains divided on that issue, and so my forecast: Congress will be so busy campaigning, dealing with internecine party wars and the uncertainty of COVID’s next move, that changes to DSHEA or MPL may be possible, but only if we find a united voice.

Health of the Industry. It has been a strong year for natural products. The sharp growth in 2020 has carried through into 2021, and my expectation is that 2022 will be equally strong. The high expectations of vaccinating our way out of COVID have given way to a more sober realization that this pandemic has become endemic—something to be managed. That realization will motivate consumers to continue seeking products to support their immune system and mood with active nutrition. In my judgment, the industry should spend far more time educating consumers on the role of innate immunity as central to resilience and healthy response to any external health threat.

Supply Chain Challenges. It was a very tough year for supply chain managers, and this will continue. The fundamentals are very complex, requiring new infrastructure (ships, dock facilities, containers and rolling stock). Labor shortages are acute. At the moment we are 80,000 truckers short. The same is true in almost every sector of the economy. This will put upward wage pressure on employers, including our industry, as will inflation, now running at a 40-year high. Despite the economic headwinds, well-capitalized companies will continue to invest in inventory. Product reformulation is now a necessary measure. The risk of economic adulteration remains ever present for high value ingredients. (Consult the ABC BAPP program for details and alerts.)

Retailing. The face of retailing has changed. It is mostly gone or behind a mask. Online sales, delivery services, and pandemics are made for each other. Instacart (or Insta-broke, as I call it) and DoorDash were and are a lifeline for many, and we will use them to lesser degrees post-pandemic. But Amazon is different. We learned this when Amazon introduced its dietary supplement compliance policy in April 2021. Many laboratories noted an explosion of calls from unknown companies needing testing to remain on Amazon’s platform. Two lessons learned: There are a legion of DS companies unknown to us who live solely on Amazon and who appear to have little or no understanding of GMPs or testing. That’s a problem. Amazon is attempting to address this. 2022 will more clearly expose the two worlds within the DS industry: digital DS and physical DS.

This brings me to the local health food store. I would be neglectful not to point out that it was the mom-and-pop health food stores that won DSHEA. It was they who held blackout days, phone campaigns, petitions, and rallies on Capitol Hill. Without the health food retailer, there is no DSHEA. Let 2022 be the year that we reacquaint ourselves with our local community health food store as customers, friends, and as allies in a common cause.

And thanks to WholeFoods Magazine who has been a champion of the health food retailer for 50 years. We salute you.

Remember What is Most Important: The Consumer

By Duffy MacKay

The unpredictable cost of doing business in 2022 is a significant challenge for decision makers in the dietary supplements industry. The rocky road of the past two years, largely due to the pandemic altering consumer behaviors, has made planning for 2022 a near impossible task. For some consumers, COVID-19 led to a focus on immune health, while others were managing pandemic-related stress or sleep issues. This led to unprecedented sales of healthcare products including vitamins, minerals, herbs, and other natural products. Legacy ingredients like vitamin D, zinc, and selenium were thrust into the mainstream conversation about fortifying the immune system to stay healthy during a modern health crisis. And a growing body of scientific evidence continues to raise the credibility of the science behind these dietary supplements, leading to more consumer interest.

However, strong, but unanticipated, sales coupled with a perfect storm of pandemic-related supply and labor shortages are set to be a major hurdle for the industry to overcome in 2022. Common ingredients, like pectin or silicon dioxide, are back-ordered. Sourcing bottles, caps, labels, and new manufacturing equipment is significantly delayed. On top of this, manufacturers around the world are trying to manage COVID-19 related labor challenges, and the sustained uncertainty is creating bottlenecks across industries.

While consumer demand for dietary supplements is predicted to stay strong, companies will need to navigate these supply chain and labor challenges to find success. The dietary supplement industry must remember what is most important: the consumer. Companies must maintain laser-like focus on advancing product safety and integrity at all levels for the benefit of consumers. For example, robust supplier qualification and supplier/manufacturer relationship management is important to maintain product integrity and safety. At the same time, informed and well-trained customer service can help communicate and manage unforeseen product delays or other changes at the consumer interface. Companies with the right internal talent, quality processes, and supplier, lab, and manufacturing relationships are best positioned to succeed.

The one thing we can anticipate for 2022 is that more consumers will purchase dietary supplements. Industry should not let the tumultuous nature of today distract us from planning for a prosperous tomorrow. To continue advancing vitamin, mineral, herbal, and other supplements into the mainstream healthcare conversation, we must advance the science, and focus on product safety, integrity, and sustainability. It’s on industry to strengthen quality assurance programs, abide by and encourage others to follow current Good Manufacturing Practices, and prioritize consumer safety to build trust in the category and products.

Quality as an Opportunity, Not a Risk

By Steve Mister
What are the greatest risks to the dietary supplement and functional food industry today? It’s a tale as old as time, and as recent as today’s headlines—quality, quality, quality.

Supplement manufacturers are faced with increasing pressure to cut corners or look the other way. Supply chain disruptions, labor shortages, and inflation all contribute to these temptations. Retailers lose sleep about potential “out of stocks,” manufacturers worry about keeping the production lines fully staffed and whether interruptions of ingredient deliveries will cause production delays. Everyone in the supply chain crunches the numbers to determine how much inflationary costs they can absorb before increasing prices to their customers. So it would be easy to let a few things slide.

At the same time, FDA has been less than vigilant recently. A substantial decline in the number of good manufacturing practices (GMPs) inspections it conducts, and the seeming reluctance to enforce even administrative violations, have led some firms to surmise the agency is a rather toothless tiger. It’s tempting to throw caution—and quality—to the wind.

But it has never been more critical to double down on demonstrations of quality production. Consumer interest, purchases, and confidence in dietary supplements are all up—CRN’s most recent survey documents that four out of five consumers have used a supplement in the past year. But while the sales figures are trending in the right direction, consumer infatuation is fickle. Consumers demand high quality and won’t forgive if they discover anything less. In the age of social media, one consumer complaint can quickly escalate to a full-scale crisis. With so many choices in the marketplace, it’s easy for consumers to discard brand loyalty if reports surface of anything that doesn’t meet expectations.

Don’t forget about the private plaintiff bar either. If FDA has been marginalized for less-than-aggressive enforcement, private litigants are all too eager to fill those shoes with their own self-imposed requirements. We are observing not only an increase in litigation targeting supplements, but new, creative theories of liability that question product integrity as well as claims. Class action suits now target products for containing more of an ingredient (not just less) than indicated on the label, or for barely perceptible levels of a contaminant.

Retailers are also developing their own programs to assure the quality of the products on their shelves, and are demanding vendor compliance. Add to that exposure the attention of state attorneys general, or the newly aggressive FTC, and the expectations of quality have never been greater.

Fortunately, this industry knows how to produce scrupulously manufactured products. Companies know how to implement GMPs, and a cadre of well-credentialed, third-party certifiers perform their own audits to assure full compliance. CRN’s Supplement Online Wellness Library (OWL) provides firms with a forum to be transparent about their products’ ingredients, labeling claims, and even the documentation behind their claims. Increasing partnerships with retailers, and collaborations on harmonized standards, give companies the tools and opportunities to show consumers just how good their products are.

My challenge to the industry is to take every chance to demonstrate the excellence of our products. I look at quality as not a risk, but an invitation. Let’s seize the opportunity.
In our 2022 Success Toolkit, industry experts share their insights and expertise on top issues to know to set you up for greater success in 2022, from trend forecast to merchandising issues, regulatory updates, and more. Start where you'd like, or read straight through:

Karen Howard, CEO and Executive Director of Organic & Natural Health Association, is a visionary and results-focused leader who has spent more than 30 years working with Congress, state legislatures and healthcare organizations to develop innovative healthcare policy and programs. She has held a variety of executive positions, including serving as professional staff for a Congressional committee, and has policy expertise in the diverse areas of integrative and complementary medicine, managed care, healthcare technology and mental health.

Loren Israelsen is President of the United Natural Products Alliance (UNPA), a trade association of dietary supplement companies committed to safety, science and quality.



Duffy MacKay, Senior Vice President, Dietary Supplements, Consumer Healthcare Products Association



Steve Mister has been President & CEO of the Council for Responsible Nutrition (CRN), the leading trade association for the dietary supplement industry, since 2005. Under his leadership, CRN has experienced increased membership each year, doubled its annual budget, sharpened its strategic focus to advance the industry, and launched new initiatives that increase industry responsibility and provide consumer education. During Mister’s tenure, CRN has been instrumental in enacting the adverse event reporting law for dietary supplements, the Designer Anabolic Steroid Control Act, and defeating several efforts in Congress that would have over-regulated dietary supplements, limiting consumer access. Mister led the association to launch the Supplement OWL, an industry-run online registry of dietary supplements and their labels.