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Dietary Supplements Council Annual Report

Founded in 2016, the aim of the Dietary Supplement Council is to provide a forum for discussing issues, challenges and opportunities related to the organic dietary supplement industry, and to develop and grow the sector in general by raising awareness and increasing access to educational materials and resources.

The Dietary Supplements Council continues to serve primarily as a roundtable for the organic supplements community to convene and discuss current topics of interest, and receive legislative and regulatory updates from Organic Trade Association staff. Milestones for 2020 included the completion of a long-term project to protect the continued availability of vegetarian encapsulated supplements certified under USDA’s National Organic Program (NOP), and establishing a collaborative relationship with the trade association’s Residues Task Force.

DIETARY SUPPLEMENT COUNCIL ACTIVITY IN 2020
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Robust information sharing and networking

The Council forum was particularly helpful in 2020, given the unprecedented year of the pandemic and the opportunity it provided for companies to engage in supportive and insightful dialogue around supply chain disruptions and learnings from the outbreak. The council also shared information and received exclusive updates from colleagues and our Regulatory Staff on National Organic Standards Board (NOSB) agenda topics and the evolving regulatory status of hemp and hemp-derived ingredients.

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USDA—NOSB--NOP Engagement: Pullulan Petition

To protect the continued production and availability of USDA-NOP certified encapsulated dietary supplements, the Organic Trade Association, with the technical support of the Supplements Council, filed a petition in January 2018 to add pullulan to the USDA’s National List of Allowed and Prohibited Substances. Pullulan is an essential ingredient used to make encapsulated vegetarian supplements. Currently, a commercial supply of organic pullulan is unavailable, and although the development of an organic version is currently underway, there are no other NOP compliant vegetarian options available.

Following the submission of the petition and comment period, the National Organic Standards Board (NOSB) engaged in its public review process and unanimously passed a recommendation to allow the use of pullulan in the designated 30% non-organic portion of supplements certified to the “made with organic ingredients” labeling category (70%+ organic). USDA-NOP accepted the NOSB recommendation, and released a Proposed Rule with a second comment period in June 2020.

Thanks to the support of the Council, including member participation in the trade association’s Pullulan Task Force, there was a strong and meaningful submission of public comments throughout both comment periods expressing continued support for the Organic Trade Association’s petition to add Pullulan to the National List. The Council expects to see a Final Rule published in early 2021. The Final Rule will mark the completion of the Council’s two-year project. However, it will continue to advocate for its ultimate goal of the commercial availability of USDA certified organic pullulan.

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Addressing Residue Testing Issues for Dietary Supplements

The Supplements Council recently established a collaborative working relationship with the Organic Trade Association’s Residues Task Force. The inadvertent or unavoidable presence of prohibited pesticide residues, heavy metals and other contaminants in organic products that can arise from neighboring conventional farms (or the environment) is a critical issue that the organic sector must continue to address. The issue is particularly complex and challenging to the organic dietary supplement sector because of the highly concentrated nature of botanical extracts and powders, and the fact that many botanical ingredients do not have pesticide tolerances, resulting in exclusion of otherwise compliant products from organic sale. Some of these ingredients used exclusively in supplements can also be challenging for laboratories to analyze, and some laboratories have not established protocols for certain crops that are not tested often.

In early 2020, the Supplements Council identified inadvertent residues in dietary supplements as a top issue of concern, and began exploring possible pathways for taking action. Because of the broad implications of residue contamination to the organic sector as a whole, an Organic Trade Association Residues Task Force was forming at the same time. The mandate of the task force is to continue the Organic Trade Association's strong support of periodic residue testing as a critical tool to monitor compliance with the organic regulations, and address challenges relating to unavoidable residual environmental contamination (UREC) and concentration factors.

Given that Councils are not policy setting bodies, the Supplements Council is positioning itself to support the work of the Residues Task Force by raising awareness around issues that are unique to dietary supplements, and to endorse outcomes that will support the organic supplements sector.

PRIORITIES FOR 2021
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Identify Challenges in Residues

Cross-collaborating with the Residues Task Force to help identify the challenges unique to Dietary Supplements and to identify and support research opportunities to address the gaps in testing and detection

Identify Challenges in Residues
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Hemp Fact Sheet

Creating a Hemp Fact Sheet in conjunction with the Fiber Council

Hemp Fact Sheet
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Developing Resources

Continuing to build out its webpage with resources and links to help educate and raise awareness on the requirements, challenges and benefits behind the formulation and marketing of dietary supplements under USDA’s National Organic program

Developing Resources
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Partner with AHPA

To support member outreach and recruitment as well as further the aim of the Council, the Organic Trade Association and the American Herbal Products Association (AHPA) are also in discussion to join forces through a formal partnership to strengthen and grow the North American organic supplement sector.

Partner with AHPA
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JOIN OUR COUNCIL MEMBERS
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MEET OUR COUNCIL MEMBERS        

 

COUNCIL OFFICERS

Jeffrey Brams of Garden of Life is chair of the Organic Trade Association’s Dietary Supplements Council. Steve Peirce of Ribus is the Vice Chair, and Genevieve Albers of Traditional Medicinals is the Secretary. The Organic Trade Association’s Vice President of Regulatory and Technical Affairs Gwendolyn Wyard provides support to the Council.

CALL TO PARTICIPATE

The Dietary Supplements Council provides ongoing opportunities for networking, leadership development, and education. If your organization is interested in learning more about its work or joining the Dietary Supplements Council, please contact Gwendolyn Wyard, the Organic Trade Association’s Vice President of Regulatory and Technical Affairs.