Those of you who follow the Organic & Natural Health Association know that we are often referred to as a boutique organization. To me that means we are designed to be elite and unique, representing only the best of the supply chain, and engaging all its stakeholders, including independent retailers and consumer organizations. We elect to tackle the very large issues that specifically relate to the health of the planet for the sake of the health of its people, several of which we recently highlighted at our 8th Annual Conference in Cape Coral, Florida.
Our agenda originates at the beginning with soil, and the tools that demonstrate a positive impact on the environment, economy, and health.
Ergo, the importance of organic, regenerative, and biodynamic, and our showcase of the first-ever organic capsule developed by Bright Pharma; RedLeaf Biologics sea-change in farming practices, and Botalys with a truly novel approach to growing Panex ginseng indoors. Our commitment to transparency and traceability requires quality, consistent testing, commitment to ingredient integrity, and the financial benefits of using blockchain technology. NJ Labs, JDS Therapeutics, and Cepham spoke to their leadership on these issues. We also learned about our newest tool for the box, the newly configured Environment, Social, and Governance (ESG) Standards that can financially reward industry corporate efforts to protect the soil, the people working the soil, and the enormous resources that go into monitoring traceability and transparency in the supply chain. Kudos to the investment experts that boldly addressed the strengths, and the risks of greenwashing, in the use of this powerful tool.
I am grateful for the efforts of these industry leaders. They have served to invigorate my energy and advocacy to affect change. Thus far, we have weathered supply chain strains and financial stress. However, external influence, specifically the introduction of synthetic biologic ingredients and products into the natural and organic space, could derail the efforts we are championing. O&N Health has been committed to educating brands, suppliers, manufacturers, and independent retailers on the science of SynBio, now known as bioengineering, for the past five years. This year’s discussion on the environmental hazards associated with the production of these products, the legal implications relating to labeling, and the importance of educating the public, reflected the enormous impact, and opportunity, that independent retailers have to ensure the integrity of food and supplements.
We have an obligation to our consumers, and the independent retailers they trust, to have the information they need, and access to quality, trusted and effective products.
We know we are being successful when independent retailers thrive.
Our frontline partners face enormous challenges. The transparency of SynBio in the supply chain will enable us to educate consumers on where they can go for quality vegan and vegetarian products. Our collaboration with SENPA is central to our success on this and on a host of FDA issues, including Mandatory Product Listing (MPL).
We are also acutely aware that Amazon, the largest online seller of dietary supplements, places the independent retailer at a disadvantage by selling fraudulent supplements to an unsuspecting public. Keynote speakers Dan Lifton, CEO of Quality of Life Labs and a member of the O&N Health board of directors, and Dan Richard, Sales Manager at NOW Foods, headlined our conference and discussion on “The Amazon Factor.” Richard shared the results of their extensive product testing that demonstrated how some companies are violating FDA GMPs, specifically around labeling, leading consumers to assume inaccurate potency. Elan Sudberg, CEO of Alkemist Labs, shared his experience and insights on the results of the testing they have been doing to support quality companies.
As Sudberg so elegantly stated, “It’s a jungle out there with so many choices, it’s almost limitless. That can be off-putting to consumers who are not yet sure what to buy and why. While limitless choice is a critical asset of Amazon, that and unparalleled convenience – and I mean unparalleled convenience – of the online experience lacks the careful curation found in brick-and-mortar stores.”
The myriad of issues arising from this testing has driven the creation of ACEP, the Amazon Supplement Claims Evaluation Program. This proposal mirrors Amazon’s Patent Evaluation Express (APEX) pilot, developed in 2018 to support patent infringement resolution (You may recall the Amazon lawsuits regarding the sale of counterfeit goods, like Cartier). The now “official” program enables brands to request evaluations for disputes of utility patents. If ACEP were adopted for supplements, it would allow a seller to file a complaint against another seller alleging that the Alleged Violator makes false claims on their product as it pertains to its nutrient content (ingredient identity or assay misrepresented on the product label) and Amazon page text copy, which can be definitively and accurately tested by independent testing labs approved by Amazon.
This is an industry-wide, complex, initiative, “in progress” and requires participation by all the quality players up and down the supply chain.
Documentation is critical. As Todd Harrison, partner at Venable LLP noted, brands must trust, but verify the work of their contract manufacturers. The Nutrasource team stressed the importance of certifying GMP compliance in methodical, measurable means. Ryan Boland, chief business officer at Mercola, was quick to point out that these fraudulent sales adversely impact the legitimate businesses that sell products to consumers. We have in our hands a remarkable opportunity to unite as an industry for the purpose of ensuring the integrity of our industry and its future. Will we be successful? In the words of Rudyard Kipling, “The jungle speaks to me because I know how to listen.” Let’s keep the conversation going.