Washington, D.C.—The Natural Products Association (NPA) is continuing to make strides in its mission of expanding access to safe products that will help consumers maintain and improve their well-being. Recently, the organization represented its members during a hearing hosted by the United States International Trade Commission (USITC) with the focus Nonfat Milk Solids: Competitive Conditions for the United States and Major Foreign Suppliers (Investigation No. 332-607). NPA CEO and President, Daniel Fabricant, Ph.D., appeared for the hearing and submitted comments in response to the investigation looking into the global nonfat milk solids market and the export competitiveness of the nonfat milk solids industries in the United States, Australia, Canada, select EU members, New Zealand, and other major suppliers.
On Nonfat Milk Solids...
There were several key points emphasized during the USITC hearing, including the contributions of NPA members to the global nonfat milk solids market, which reached $10.5-12.5 billion USD in 2024 and is projected to expand to $15.2-18.7 billion USD by 2033. This market's compound annual growth rate of 4.8-6.59% is driven significantly by increasing demand from the dietary supplement space.
In its written testimony, NPA explained: "Members of the Natural Products Association specialize in manufacturing whey protein, probiotics, and colostrum-based dietary supplements, making us heavily dependent on reliable access to high-quality nonfat milk solids. The dietary supplement industry represents a rapidly growing segment of the nonfat milk solids market, with robust demand for specialized applications including whey protein concentrates, dairy-based probiotic formulations, and colostrum supplements."
NPA also underlined the impacts felt, from a policy standpoint, by shifts in government regulations, trade agreements, and export controls affecting nonfat milk solid products. "Regulatory changes, such as those associated with the USMCA in North America, directly impact the ability of supplement companies to maintain reliable ingredient sourcing, which is vital for ensuring continuity in both domestic and export product lines."
For more on the USITC investigation into Nonfat Milk Solids, visit usitc.gov
On HSAs/FSAs...
Earlier this month, NPA contacted the Billy Long, Commissioner of the Internal Revenue Service (IRS), on behalf of the group's 500+ member companies, congratulating Long on his appointment to the position and to call for a modernization of IRS Publication 502 to expand qualified “medical expenses” to include nutritional and dietary supplements that carry FDA-authorized health claims, or structure/function claims.
NPA explained in the letter: "This critical update would allow consumers to use their Health Savings Accounts (HSAs), Flexible Spending Accounts (FSAs) and Health Reimbursement Arrangements (HRAs) without first obtaining a prescription."
The communication went on to point out the areas of improvement available within the current policy, discuss how revisions made in the year 2000 no longer reflect the evolution of federal supplement oversight, scientific substantiation, or consumer behavior, and explain how NPA's proposal of including dietary supplements within the cost of medical expenses aligns with current policies including the Make America Healthy Again (MAHA) movement.
NPA noted: "This modest change would modernize a 20th-century rule to reflect 21st-century science and consumer health behavior, without changing the underlying statute or regulation. Allowing Americans to use their HSA, FSA, or HRA dollars for scientifically substantiated supplements without a prescription would:
- Promote preventive care.
- Reduce unnecessary health system burdens.
- Support health equity by improving access.
- Reinforce personal responsibility in managing health.
The IRS has a unique opportunity to advance health freedom and consumer choice, core principles of the Make America Healthy Again movement by making this simple, targeted revision to Publication 502."
A complete version of the NPA's letter to Commissioner Long can be read here.
