CRN launched the campaign in September as a “celebration of self-regulation in the dietary supplement industry to recognize the association’s longstanding work in this area.”
In addition, the campaign aimed to remind CRN members of all these [self-regulatory] programs and where to find the [voluntary guidelines and best practice] documents and to invite non-members to look at them and think about doing them as well, Mister told NutraIngredients-USA.
The association has established a tiered system of self-regulatory directives. Adherence to the most important provisions is required of CRN members, such as participation in the Supplement OWL dietary supplement product registry.
The next level down includes an assortment of voluntary guidelines, best practices and considerations that members are urged to comply with within a specified time frame after adoption and approval, Mister said.
Three degrees: Voluntary guidelines, best practices and considerations
CRN defines the differences between these self-regulatory efforts on its website. In short, voluntary guidelines are developed via an extensive process that begins with an initial proposal, then exploration by the executive or a committee, and then a blessing from CRN’s Board to form a task force. The membership is then invited to join the task force but only if they have a product that falls into the appropriate space. Once the task force delivers its conclusions, it goes to a committee and then on to the Board for adoption, he said.
“CRN considers Voluntary Guidelines to reflect the standard for industry practice,” CRN explains on its website. “They should be specific, measurable, achievable and able to be fully implemented by all members of the industry.”
These guidelines involve a lot of consensus building, said Haiuyen Nguyen, vice president regulatory and nutrition policy at CRN. “Some members are willing to push more than others.”
“One of the challenges is that sometimes there’s a tendency to water down the standards to a restatement of the law, the federal requirements,” Mister added. “That’s not the point. We push against any watering down. The point is to push the industry forward.”
The process takes at least six months, with the goal to always wrap it up within a year. “We’ve walked away from things where there’s no consensus,” he said.
Best practices are aspirational and are recommendations that exceed federal requirements that “best in class” companies in the industry should follow. While they are recommended for CRN members, they are not a condition of membership.
Considerations are defined as items a CRN member should consider in relation to a specific topic, such as product development, marketing, manufacturing processes or other practices. They are neither an industry standard nor an expectation for membership, says CRN.
Collaboration
Mister noted that some of its efforts are developed in conjunction with other associations, like the best practices for probiotics, first released in 2017 and developed with the International Probiotics Association.
CRN also worked with the Enzyme Technical Association for its best practices on enzymes, he said.
Nguyen noted that CRN is currently reviewing all its existing voluntary guidelines and best practices to ensure the documents are keeping up with the evolving science.
But why?
Mister told us that there are many reasons why projecting responsibility is beneficial for companies and the industry as a whole. Indeed, he explored 11 reasons in an extensive article published in Nutraceuticals World.
“Self-regulation does not eliminate companies’ need to comply with various laws and regulations governing dietary supplements, but it does build confidence among consumers, healthcare professionals and other stakeholders,” Mister wrote in that article. “Being ‘responsible’ means instilling self-restraint, accountability and integrity in our businesses.”
