Bill Bookout, president of the National Animal Supplement Council (NASC), fields five to six calls per week about hemp and CBD for pet supplements.
The Hemp Farming Act, passed as part of the 2018 Farm Bill, removed the DEA component associated with hemp and allowed segmentation of the plant to include the use of flowering tops and resins where the full-spectrum cannabinols are found. Hemp and CBD are unapproved for use as an animal food ingredient, said Bookout.
For foods, beverages, and dietary supplements, the US Food and Drug Administration’s position that CBD is not a permissible ingredient in a food, beverage or supplement because it was the subject of an Investigational New Drug (IND) application (by GW Pharmaceuticals, which markets the approved CBD drug Epidiolex for the treatment of seizures associated with two rare forms of epilepsy) and was not marketed in foods prior to that application.
NASC’s position is that hemp is allowed in dosage form products (ie. supplements) provided it doesn’t contain CBD concentrates, isolates, or synthetics, and the THC content is 0.3% or less. This does open the door to products with formulated with hemp ingredients, he said, just not with CBD concentrates, isolates, or synthetics. In addition, they should be labeled as hemp, but brands can mention that they contain naturally occurring full spectrum CBD.
Beyond CBD, innovation in the pet supplements space has focused on delivery systems and there’s always interest in proprietary ingredients, said Bookout.
Delivery systems and proprietary ingredients
“It’s difficult to better chewables as a delivery format,” he told us. Brands also want proprietary ingredients protected by IP and market exclusivity, but those don’t come along very often.
In order to get new ingredients into the sector, NASC requires companies to submit a safety study in the targeted species to their scientific advisory committee for review. “We probably receive fewer than six per year,” he said.
While many of the ingredients cross over from human supplements to animal supplements, the regulatory framework for animal supplements is different. DSHEA (the Dietary Supplement Health and Education Act) does not apply to animals, so for the pet/animal supplement area, we live in a pre-DSHEA environment.
Animal supplements are regulated at three levels, explained Bookout: One they’re regulated by the FDA’s Center for Veterinary Medicine; they can also be regulated by the States; or NASC has developed a system of self-regulation. NASC, with over 280 members, represents about 90% of the animal supplement industry.
NASC has a very thorough and comprehensive system of self-regulation that we have worked to define, develop, and implement working very openly and transparently with the regulatory agencies at both the State and Federal level.
The market for supplements for pets is valued at around $2.6 billion, said Bookout, split $1.4 billion for dogs and cats, and $1.2 billion for horses.
“The growth and activity in the category over the last couple of years has been more significant than I’ve ever seen it,” he said. “It’s very dynamic.”
So what’s driving this? People recognize that the category is pretty recession proof, and the demographics are changing: At one of the age spectrum, you have higher numbers of empty-nesters and on the other end, you have Millennials who are delaying having children, or deciding not to at all. Both scenarios are leading to more pets and greater investment in the health and wellness of those companion animals, he said.
According to a February 2015 report by Packaged Facts (which captures dogs, cats, birds, small mammals, and reptiles, collectively), joint health supplements are the most commonly purchased condition-specific pet supplement, followed by heart health and skin and coat health, then digestive health/hairball prevention, and omega fatty acid supplements.
While Bookout agrees with these condition-specific claims, he disagrees with the Packaged Facts’ prediction that “functional treats” could emerge as a challenge to supplements.
“I think this is limited,” he said. “By definition, treats are a food or a feed, and therefore have a more limited list of ingredients. Most ‘functional’ ingredients like glucosamine, turmeric, lutein would not be allowed in treats for functional health benefits.”
The NASC was founded in 2001 with a mission, “to promote the health and well-being of non human food chain animals that are given animal health supplements, by establishing federal and state regulations that are fair, reasonable, responsible and nationally consistent.”
Over the years the association has established an impressive self-regulatory framework, which includes GMP standards, an AER system, a preferred supplier program, labeling claims guidance, continuing education, and more.