Can a Registry Build Trust?
The good news is that the dietary supplement industry remains relatively trustworthy in the eyes of U.S consumers. Despite some of the recent challenges, CRN’s 2016 consumer survey revealed that 73 percent of Americans (that’s all Americans, not just the ones who use our products) perceive the supplement industry as either somewhat or very trustworthy. So despite the reports of tainted products containing illegal drugs, attorney general investigations, and studies purporting to indicate supplements are unnecessary, consumer confidence in the industry has remained relatively stable—and sales data further support that.
But of course, that can change quickly if we don’t constantly work to earn that trust. The supplement marketplace is particularly vulnerable because we are, after all, in the healthcare business, so the expectations are higher than for other consumer goods. People purchase dietary supplements with the expectation that they will help keep them healthy; every time a consumer opens a bottle, pouch, or blister pack and puts one of our products in his or her mouth, we take our place as a provider of healthcare.
For today’s consumers, trust is closely linked to transparency—if you appear to be hiding something, they suspect the worst. At the same time, the FDA, the agency charged with regulating this industry, openly acknowledges it doesn’t know which companies market which products, and which products contain particular ingredients. How should regulators identify which manufacturers to contact if a particular ingredient shows signals of adulteration? How do retailers evaluate which products meet their quality expectations? We need a product registry to shine some daylight on the industry.
Introducing the Supplement OWL (Online Wellness Library), a dietary supplement finished product registry—an industry-wide, self-regulatory initiative that will help create a rich and more complete picture of the marketplace for regulators, retailers, industry itself, and, ultimately, consumers. It will serve as a resource to identify, examine, and evaluate product labels and information.
The Supplement OWL is an initiative of the dietary supplement industry, propelled forward by the Council for Responsible Nutrition (CRN), but the product of many voices working collectively to bring it to life. At its core, the OWL seeks to answer the questions: What does the supplement marketplace in the U.S. look like? Who markets which products? Which ingredients do they contain? Admittedly, the Supplement OWL will not solve all the criticisms leveled against the industry, but knowing the universe of marketers, brands, products, and ingredients is the first step to sustaining trust. And it establishes a platform on which other self-regulatory programs can be built.
The Supplement OWL will consist of two tiers; the first is completely free to any company that wants to participate and is willing to provide the required data. Tier 1 information will include basic information about the product, much of it culled from the label itself: brand name, product name, product category, delivery description, intended users, ingredients, Daily Values, serving size, label claims, precautionary statements, storage information, seals and certifications, and allergy statements. Each entry will also provide a product image and a copy of the label, as well as a unique alpha-numeric identifier. Anyone with an internet connection, including our regulators, will have access to Tier 1. In addition, FDA will have access to Tier 1 plus the manufacturer/packager information (either names of manufacturer and packager or 24-7 contact information for a person who will provide this information).
Tier 2 will include supporting materials that verify the information on the label: product specification sheets, verifications of product attributes and certifications, and evidence of third-party audits for GMP compliance. Tier 2 is accessed on a “permission only” basis, intended largely to address the needs of retailers seeking to qualify products for sale.
Development of this registry is well underway. The Supplement OWL is already receiving labels from companies and is expected to go live in April.
Once realized, the Supplement OWL will provide a snapshot of the vast array of healthful products that compose the supplement market and demonstrate the willingness of this industry to proactively self-regulate. It will strengthen the industry’s relationship with the FDA by improving the agency’s ability to obtain product, ingredient, and manufacturer information quickly and eliminate the charge that FDA cannot determine, the size and breadth of the industry. The OWL will assist retailers to more easily evaluate dietary supplements and select quality products for their customers. And ultimately, it will permit consumers to identify and evaluate dietary supplements based on labeling, contents, and indicia of quality—to more wisely “navigate the aisle.”
Building and maintaining trust means assuring even our critics that we have nothing to hide. Making product labels accessible in one place demonstrates confidence that our products and labeling comply with the law. In this era when consumers are demanding more visibility about the authenticity of everything they purchase, the Supplement OWL is an opportunity to give our many stakeholders a clear view of who we are. Will you join us as the Supplement OWL takes off and soars?