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Dietary Supplement Label Roll Call re: Voluntary Product Registry for Dietary Supplements

Leading dietary supplement trade association to require all members to submit product labels to centralized database.

  • A leading dietary supplement trade association — the Council for Responsible Nutrition (CRN) — has been pursuing the goal of creating a Voluntary Product Registry for Dietary Supplements.  According to CRN, the goal of the registry is to increase transparency and give regulators greater access to information about the composition of supplement products currently on the market.

  • As a first step in creating a centralized label database, CRN will be requiring all member companies to submit their supplement product labels to the Dietary Supplement Label Database (DSLD) currently maintained by the National Institutes of Health (NIH) Office of Dietary Supplements (ODS).  The requirement will apply to member companies listed as the responsible party on the product label and will take effect in 2017.  CRN has some concerns about the robustness of the current NIH database and has submitted comments to ODS requesting improvements such as increased processing capabilities, a more refined product numbering system, and a clear process to govern label updates and the removal of errors from the database.  CRN also proposes to provide non-public information (to which only FDA would have access) about the parties who manufacture and package products in the DSLD, which could be useful to the Agency where the party named on the label serves only as the distributor.

  • CRN is the first trade association to require its members to submit labels to a centralized repository, although others may follow suit.  For years, good actors in the dietary supplement industry have worked to counteract the negative publicity associated with the marketing of illegal or tainted products.  The full impact of this concrete step toward transparency — both in terms of public perception and regulatory scrutiny — remains to be seen.

© 2020 Keller and Heckman LLPNational Law Review, Volume VI, Number 19
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Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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