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AOAC ERP of the Year to Kombucha Alcohol Group

NaturPro Contributes to Expert Panel Receiving AOAC Award: “ERP of the Year” to Kombucha Alcohol Group

The AOAC Expert Review Panel (ERP) charged with reviewing methods of analysis for ethanol in kombucha initially met in September 2016 to review methods against AOAC SMPR 2016.001 (Determination of Ethanol in Kombucha). At this meeting, the ERP adopted an Official Method of Analysis for First Action status, AOAC 2016.12 (Determination of Ethanol in Kombucha) using gas chromatography with flame ionization detection (GC-FID). The selection and validation of this method was coordinated by NaturPro Scientific and performed by Covance Laboratories, Wisconsin.

kombucha tea testing alcohol ethanol

Method adopted for kombucha tea testing for alcohol in validated labs

AOAC states: “The ERP’s work directly impacts the resolution of urgent and key issues identified by industry, and serves as a forum where both the kombucha industry and government work together.

“The ERP was selected because its open and thorough scientific scrutiny of methods and its output clearly demonstrate the culmination of an industry-wide effort that facilitates regulatory and industry engagement for addressing urgent analytical disputes and facilitating trade. All ERP members receive the award, and publicly receiving the award on behalf of the group is the ERP chair, Sneh Bhandari.

“The Expert Review Panel (ERP) of the Year Award recognizes an ERP for achieving and completing signicant milestone(s) (e.g., Final report, First Action Method, Final Action Method), highlighted by some unique or particularly noteworthy aspect of a review panel report, such as innovative technology or application, breadth of applicability, critical need, difficult analysis, or timeliness.

“The report demonstrates significant merit as to the scope of the project, diversity of the panel, or an innovative approach to difficult analytical challenges. The report must have been submitted within the last 3 years.”



NaturPro Comments to FDA on the Safety of CBD

by NaturPro in Quality Comments: 0

Date: September 14, 2017


From: Blake Ebersole, Carmel,  Indiana  email:

Re: Entire Comments for The Food and Drug Administration (FDA) Notice: International Drug Scheduling; Convention on Psychotropic Substances; Single Convention on Narcotic Drugs; Ocfentanil, Carfentanil, Pregabalin, Tramadol, Cannabidiol, Ketamine, and Eleven Other Substances; Request for Comments

To Whom It May Concern:

I strongly urge you to consider all available evidence to deschedule CBD and hemp-based products, permitting them to be regulated like similar products.

I was only slightly surprised to see FDA seeking comment on CBD, among a list of highly addictive and unsafe substances. It was telling that the other substances on the list are prime examples of a U.S. healthcare system that has repeatedly failed to adequately provide for its people, and that many consider CBD to be a potential solution.

I am in full support of common sense regulations for the use of CBD and other cannabis derived products, as part of foods, dietary ingredients and medicines, especially where they are benchmarked to similar requirements for these regulated products.  I have observed, attempting to be as objective as possible, that cannabidiol (CBD) and related cannabinoids, appear to be safe, tolerable and effective across a wide range of doses, in both adults and in children who are healthy, as well as those with the occasional ache or pain, in addition to those with severely compromised health conditions.  CBD is likely to be safe, and I understand there has already been significant research to support its safety on a level with other permitted food additives or dietary ingredients.

For the past 10+ years, I have managed R&D, scientific, FDA regulatory and compliance activities for natural and plant-based products used in supplements, foods and medicines.  For the past three years, I have consulted to support standards development for CBD and cannabis, supporting various government, NGO’s and responsible industry members.  I have helped with qualification and production processes for CBD using FDA GMP’s for food and supplements, as well as state and local regulations. I have also audited analytical laboratories testing programs for cannabinoids and contaminants, and have reviewed much of the published toxicology and clinical data.  Initially a skeptic of the therapeutic potential of CBD, my mind has gradually changed after personal communications with more than one hundred people who have tried either cannabidiol alone, or in combination with THC or marijuana.

CBD does not offer the psychoactivity, the ‘high’ or addictive potential of THC. In fact, it is well known among recreational marijuana users that CBD dulls the euphoric effect that is typically the goal of recreational marijuana use. Although CBD is being sold in marijuana products in states that permit marijuana, (overwhelmingly by people who use marijuana for legitimate medical reasons), the only use of CBD outside the state-run marijuana programs are from hemp-derived materials which contain only trace to very low levels of THC – not enough to cause a ‘high’ or euphoric effect.  In general, products which contain a predominant amount of CBD do not also contain any appreciable amount of THC considered significant or helpful for a recreational user.  The use of CBD as recreational is therefore very limited. Surprisingly, the predominant use of CBD recreationally is as a substitute for marijuana, alcohol or prescription opiate use.  The handful of published clinical studies on CBD and cigarette smoking cessation are consistent with these anecdotal reports, suggesting that part of the potential of CBD lies in its apparent ability to reduce or replace marijuana, alcohol or drug use and abuse.

I have never heard from so many people with complicated, unresolved health conditions, who claim that a non-pharmaceutical intervention completely changed their life for the better.  As the most frequent example, CBD appears to work for a large percentage of people with chronic pain or debilitating inflammatory or autoimmune issues who don’t respond to NSAIDS, and who are afraid of (or have been addicted to) opiates. Until the pain management and the resulting prescription opiate problem is resolved in the U.S. CBD should be considered a front-line natural remedy, much like turmeric, fish oil, glucosamine or aspirin has already been found effective for by millions of Americans.

CBD appears to support a number of health conditions that span healthy, pre-disease and disease states.  CBD, both with or without THC and other cannabinoids, has been a life-changer for untold thousands of people.  CBD clearly has a potential for therapeutic use, in most cases significantly improving quality of life for people who have not found any solutions in the conventional healthcare system.  Notwithstanding the clear therapeutic value of marijuana and THC that was outlined in the National Academies of Sciences Institutes of Medicine analysis titled “The Health Effects of Cannabis and Cannabinoids: The Current State of Evidence and Recommendations for Research” published on January 12, 2017 and located at, CBD has also immense promise, subject to a number of human and animal studies conducted outside the U.S. for more than 50 years.

I have personally observed the cultivation and manufacturing practices of many firms as a quality management consultant, and I have also supported the development manufacturing processes and quality management systems for CBD products that are legal under relevant and appropriate regulations, which meet the already established food safety requirements required by FDA.  Existing cultivation and production processes around the globe have reliably produced hemp and cannabis products that are safe for human consumption. The quality and safety of these products will only improve under existing regulations, like those in place for dietary supplements.

As a regulatory compliance consultant, one issue I can understand is the inability for regulators to determine whether a cannabis plant is industrial hemp, or marijuana. However, the answer to many for this issue is clear: there currently exist valid methods for testing samples to the 0.3% THC threshold that defines marijuana by law. Because most CBD products and raw materials do not contain more than 0.3% THC, it should be easy for industry and regulators to discern a federally legal product from an illegal one. I have coordinated analytical testing on CBD products as a consultant for identity, potency  and impurities such as pesticides, residual solvents, and microbiology, and I have found these labs meet the same requirements expected of FDA-regulated food and supplement industries. There are several labs in the U.S. who are capable to perform testing for CBD products, and use validated analytical methods yielding reliable results, meeting general requirements for method validity, as per AOAC, FDA and other applicable guidelines. I have also not observed the types and levels of contaminants any different from those found in foods and dietary supplements.  In many cases, CBD products meet dietary supplement requirements, even if they have not been required.

Cannabis cultivation and oil production present a minimal level of food safety risk.  Because water is rarely (if ever) used to process raw plant materials, or extract oil-based products containing CBD, issues with waterborne pathogens are unlikely. The lack of clear regulations for CBD products does pose a potential threat to public safety, however. Due to the CBD gray market that has grown overnight, and the low barriers to entry for these as well as food and supplement products, there are presumed to be many small manufacturing facilities that are under the radar, who have not been inspected or registered with state or FDA agencies. These facilities may be performing packaging of end products that do not have the quality management programs or preventive controls required to ensure product safety in today’s world. Therefore, it is important for regulators and industry to work together toward responsible and appropriate regulations that would require a similar level of control to those found for food or dietary supplements.

CBD enjoys a likely long history of human consumption, which unfortunately is not well documented. There is a strong case that humans have historically consumed CBD as part of cannabis remedies, along with THC, since both are the predominant cannabinoids present in hemp and marijuana. Presumedly, the content of CBD in hemp varieties that were historically used as fiber and medicine, particularly those grown in eastern Europe and South Asia continuously for the past century, reflect a composition containing a substantial amount of CBD.   It is possible that the pre-modern medical use of hemp as pain relief was due to CBD activity in addition to THC or the other cannabinoids or constituents that are naturally occurring in the hemp and cannabis plants.  It is also scientific fact that humans and animals possess receptors for which cannabinoids from plants serve as ligands. There are few (if any) plants with such a long-time history of widespread human consumption, for which there have been specific receptors identified in the body.  Simply, the story of cannabis and human’s voracious consumption of it should be part of any risk-based analysis of its modern use.

Of course, there are many poisonous or addictive natural products which are banned, just like there are many harmful ones that are legal: tobacco, alcohol, and caffeine are widely accepted as being helpful for everyday life, and these enjoy the benefits of common sense regulations.  It is absurd to consider marijuana worse than these substances, and without any accepted medical use under Schedule 1.  It should be considered an even more criminal act that CBD is considered in this same list, conveniently lumped under the umbrella of marijuana. To me, this represents a deliberate suppression of our freedom to pursue life, liberty and happiness that was granted by our country’s founders.

In my view, and I believe in the view of many other scientists and physicians who have also seen first-hand the health outcomes with CBD use, the benefits of CBD far outweigh the risks.  I urge FDA to carefully learn and consider the benefit versus the risk to permitting CBD products under an existing regulatory guideline, such as that for dietary supplements (21 CFR 111). As a second, but less attractive option, state-led regulatory efforts under legal recreational and medical marijuana, are rapidly becoming equipped to handle CBD products, despite the absence of federal support.

Although economic development is outside the scope of this comment, you may have heard that CBD is made from hemp, which many believe could have a major economic impact on America’s farmers and reduce our reliance on fossil fuels.

I strongly urge you to consider all the comments on this board, and your duty to promote public safety, and deschedule CBD and hemp-based products, permitting them to be regulated like all other similar products.

Blake Ebersole
NaturPro Scientific LLC
Carmel, Indiana

Nutraceutical Research Study Sign-Up

NaturPro is currently conducting a research survey on a transdermal patch containing plant extracts that may improve focus and performance during occasions requiring optimal mental or physical performance.

 The survey includes healthy volunteers aged 18-39 who exercise regularly to provide survey information on their mental and physical states, both before and after one week trial of a transdermal patch containing natural and safe ingredients that support physical stamina and mental focus.

Participants will be paid $100 to complete this week-long survey. 


Apply Here:

Please enter your phone number to be contacted about the research survey.


This survey is being conducted to determine whether a transdermal nutraceutical skin patch containing natural and safe ingredients that may improve performance and mood endpoints in people who exercise regularly.

  1. The survey requires you to be healthy and physically active, and between the ages of 18-39.
  2. You are not on any medications for any diagnosed medical conditions.
  3. You are not pregnant or lactating, or currently taking any hormones, steroids, or performance-enhancing drugs or supplements.
  4. You have exercised at least 3 times per week, for at least 20 minutes per day, for the past month.
  5. You pledge to not change any of your dietary or exercise behaviors for a week before, or during the 7-day study.
  6. You pledge to conduct the surveys honestly and comply with all the requirements.
  7. You pledge to truthfully report any positive effects or improvements, as well as any side effects, adverse events, illnesses or injury occurring during the study, whether they are attributable to the study treatment or not.
  8. This survey is to be completed twice: the day you begin using the transdermal nutritional patch, and one week (7 days) after applying one patch per day.

SURVEY MEASUREMENT: The survey is based on validated clinical measurements for mood and exercise recovery. The survey is conducted on Survey Monkey, and all results are encrypted and kept private according to the strictest privacy standards.

SURVEY PRODUCT: The patches are made of non-latex, non-allergenic, pharmaceutical grade materials and adhesives, that will be commercially available in early 2018

  1. Make sure the patch is affixed to clean, dry skin, on your shoulder, upper back or thigh. Do not apply anything else to the skin, such as lotions or moisturizers
  2. Remove the backing of the patch, and firmly stick the the treatment patch on your shoulder, upper back or thigh, in the morning.
  3. Keep on for at least 8 hours per day, including during training, work or competition.
  4. The patch can be kept on during bathing or showering, or sleeping
  5. Do not remove and replace the same patch on another part of your body.
  6. The patch should not fall off, but if it does, report this in the survey and replace with a new one.
  7. You may keep the patch on for longer than 8 hours, for up to 24 hours.
  8. You must take the end-of-week survey in the morning, within 16 hours of removing the last patch.

POTENTIAL RISKS: This study will entail zero to very limited risk to subjects. The study treatment is a transdermal patch containing all ingredients plant-based ingredients commonly consumed orally in dietary supplements. The patch is made in a facility that employs Good Manufacturing Practices (GMP).  No blood or other biological specimens are taken in the study. The measurement tool is an online, web-based survey using a validated clinical measurement of mood, focus and exercise recovery. Some subjects may receive a placebo or ‘dummy’ patch. If you are in the placebo group, you will be notified after the study to receive a free 7-day supply of the active treatment.

TREATMENT PRECAUTIONS: Reported cases of skin irritation with this product or its ingredients are extremely rare. People with sensitive skin or who experience irritation from plant-based extracts or essential oils may be sensitive to the treatment product.

POTENTIAL BENEFITS: Subjects in the active group may perceive better focus, performance, mood or stamina as a result of the treatment.

 COMPENSATION: You will be paid $100 after completing both online surveys one week apart. Payments will be sent to you by check within 2 weeks of study completion. You must complete every part of this survey two times, both before and after the 7-day study, to receive compensation.

CONTACT: This study is conducted by NaturPro Scientific LLC. You may contact the study coordinator, Blake Ebersole, at anytime at blake@npscientific, or by phone at (317) 727-9173.

PRIVACY: Your personal information is kept private, and we will not sell or give out your contact information. We adhere to all HIPAA and standard medical practices for patient information privacy. If we choose to publish the results of the study, the results will be reported as an average of all participants, and your personal information will not be disclosed. We encourage comments at the end of the survey; you consent for your comment to be published, without any personally identifying information. We require your phone number so that we may contact you to confirm your interest and answer any questions.  Your mailing address is used to ship to study materials (transdermal patches) to you, and will not be used or shared for any other purpose.


Food and Supplement Product Manufacturing Feasibility

Knowing whether a material will be able to be made into a product is a key step to product development. A lot of natural products are unstable, insoluble, non-flowable, terrible tasting, or otherwise challenging to mix into the desired product form.

In today’s ‘clean label’ demanding market, many of the additives used to make a high quality tablet or beverage are no longer salable.

Food and Supplement Product Manufacturing Feasibility

Related to the exercise of understanding manufacturing feasibility, we also offer a number of production-related services:

  • Source and qualify bulk raw materials
  • Raw material quality verification program
  • Supplier verification program
  • Facility design and GMP
  • Formula/recipe development
  • Project management
  • Manufacturing process design
  • Equipment qualification, sourcing, IQ/OQ/PQ
  • Contract manufacturer qualification
  • Materials selection & sourcing
  • Packaging & label development
  • Documentation & systems

NaturPro’s core experiences are in understanding how to make better products and better ingredients. Contact us to learn more.

Food and Supplement Product Manufacturing Feasibility

Food and supplement product manufacturing feasibility is the first step in understanding whether the product of your dreams can become a reality.

The Regulatory Patchwork of Dietary Supplements

by NaturPro in Quality Comments: 0

In the United States, dietary supplements and their ingredients are subject to a patchwork of regulations, industry guidance, voluntary certifications and audit programs. With some exceptions, few standards for dietary supplements have been developed with expert consensus and  broadly implemented by the dietary supplement industry.

FDA’s dietary supplement GMPs (good manufacturing practices) are part of the exception and have made today’s supplement products generally a higher level of quality than at any time before.

Dietary Supplement Deming Opinion

In Dietary Supplements, Data is Needed to Support Compliance

Making A Quilt from the Regulatory Patchwork: What Successful, Resourceful Firms Do

Yet few industry standards are clearly understood, consistently applied and sufficiently comprehensive to cover all the ground.

One primary example is the gap between compliance requirements for dietary ingredients (under food GMPs) and dietary supplements, whose GMP framework is derived from that for pharmaceuticals. The underlying litmus test for the level of safety demanded for supplements and foods are different—that of “non-adulteration” versus “safe for human consumption,” Respectively. Maybe due to the differences, supplement GMP audit programs can overlook the food GMPs that govern ingredients. It is not uncommon for a manufacturer and a supplier to speak completely different quality languages. Audits for supplement GMPs are frequently unable to determine to a reasonable degree of certainty whether a particular ingredient, based on its certificate of analysis (CoA), should be expected to meet supplement requirements once it is placed inside a capsule or tablet.

As could be expected, an unintended consequence of this major gap is the common practice of a raw material CoA being duplicated as the manufacturer’s raw material specification.

In this scenario, an ingredient specification has been developed according to food requirements and, often without further analysis or verification, it is assumed to meet the requirements of the finished supplement. The result is a supplement that is essentially of no better quality than the “food-grade” ingredients put into it.

Especially for botanicals and animal-derived raw materials: cultivation, harvesting and processing before the final ‘transformation’ adds another dimension..

Confirming identity and purity is a complicated problem, particularly for a global supply chain of agricultural materials susceptible to contaminants during farming, harvesting, processing, storage or transportation to the ingredient processing facility.

In many poorer countries, the supply chain, and contaminants are not as well regulated as in advanced nations, and are freely shipped with no knowledge of their destination. Likewise, the final manufacturer or end user may have no information on the source of the material beyond the previous dock. In an uncomfortable way, the U.S., with its more lax regulations, often receives the materials rejected by Europe. Thus, potential contaminants may not be necessarily listed on the specification or controlled by the food GMPs, yet they can cause the products to which they are added to be adulterated.

Dozens of standards have been written for agricultural products, many of which don’t (or can’t) apply to the small family farmers who are a predominant source of botanical raw materials. In addition to recent requirements for fresh produce established by the Food Safety Modernization Act (FSMA), which don’t really apply to dried agricultural materials, we also have: USDA good agricultural practices (GAPs), which are intended for large farms and seldom fully practiced in the United States; certified organic, which requires no testing for contaminants like pesticides that may cause a product to be adulterated; independent farm standards like Global GAP, which arealso intended for large, modernized industrial farms; and, dozens of good agricultural and collection practices (GACPs) for medicinal plants that have been independently written by various nations and trade groups.

Some experts say the mess of standards, the dynamics of the industry and the law of entropy do not support the possibility of a clear and unified regulatory structure.

Others recognize the limitations, yet remain busy sewing the patches together into a quilt that is greater than the sum of its parts.


initiatives are in process or recently completed that contribute to the integrity of our industry quilt and have provided free information. Just in the past couple years:

•             The U.S. Pharmacopoeia (USP) and American Herbal Pharmacopoeia (AHP) developed monographs and methods for testing dietary supplement ingredients.

•             USP also developed a Food Fraud Mitigation Database that lists adulterants common for food ingredients.

•             AOAC International developed analytical methods for dietary supplement ingredient potency and contaminants.

•             The National Institutes of Health’s (NIH) Office of Dietary Supplements (ODS) website became a valuable source of information and resources.

•             Trade groups such as the American Herbal Products Association (AHPA) and American Botanical Council (ABC) made enormous efforts to educate and guide the industry on issues around botanical dietary ingredients and adulteration, including a recently updated draft GACP from AHPA, and the ABC-AHP-National Center for Natural Products Research (NCNPR) Botanical Adulterants Program.

•             The Supplement Online Wellness Library (OWL) was established by the Council for Responsible Nutrition (CRN), to allow labels for supplement products on the U.S. market to be put into in one place.

•             The Supplement Safety and Compliance Initiative (SSCI) was formed as a broad industry initiative, with wide support from trade associations, to address some of the gaps for supplements that aren’t sufficiently covered under other standards. SSCI is led by experienced players in retail, manufacturing and supply, and includes a focus on identity, risk assessment and quality for raw materials.

•             In response to consumer demand, leading retailers, manufacturers and ingredient suppliers invested significant resources into traceability and quality, and are now able to make meaningful claims to these effects that are not only important to consumers, but also serve as a reliable way to differentiate from the competition.

Today’s movement toward a greater level of education and transparency includes a firming of the gaps, especially where raw material traceability and quality are concerned. Successful companies across the entire supply chain are actively improving and adopting new standards, building a level of quality and integrity that provides lasting value to their business. Those who are upping their game are piecing together a quilt of their own, leveraging their quality advantages into claims that deliver marketing value. On the other side, those who continue to rely on ignorance or a lack of regulatory clarity as reason to take no action are increasingly left behind.

In an industry where faceless online product marketers are more common than they should be, and where a list of the tens of thousands of products available on the market is just getting online, our combined efforts to fill in the gaps of the collective regulatory patchwork benefits everyone.

This article was previously published in Natural Products Insider, July 2017. 

Dietary Supplement Ingredients and Raw Materials

NaturPro Scientific are experts in dietary supplement bulk raw materials and ingredients, especially botanicals and herbs.  We know how botanical and medicinal plants are grown, harvested, aggregated, processed, extracted and tested.

We are specialists in qualifying, testing and sourcing herbal dietary ingredients and botanical raw materials used in supplements, foods, pharmaceuticals and cosmetics.

Quick Facts on Bulk Supplement Ingredient Formats, Quality, Testing 

  1. Most raw materials are available as whole, cut, powdered or powdered extract. We recommend and specialize in fully standardized botanical extracts with full supply chain traceability and transparency, meeting the strictest global requirements.
  2. For non-botanicals, we suggest working directly with the manufacturer, and not with a distributor. All certificates of analysis should list the manufacturer’s name and the address of the manufacturing facility where the product was produced, or be accompanied by traceability documentation.
  3. Many raw materials are available as Certified Organic. Most products are naturally non-GMO.
  4. All materials may be tested at dedicated laboratories for the presence and amount of nutrients, potency, microbiology and pathogens, heavy metals, pathogens, 500+ pesticides, 100+ volatile organic compounds and solvents, food allergens and gluten, and mycotoxins.
  5. The testing plan is based on the material specification, which is typically based on the regulatory requirements of the country where the materials will be sold.
  6. We also recognize and actively seek out materials meeting various benchmarked quality standards, such as U.S. 21 CFR 111, USP <561> Articles of Botanical Origin and official pharmacopeial monographs, WHO Good Agricultural and Collection Practices (GACP), USDA Good Agricultural Practices, Fairtrade,  U.N. Forum on Sustainability Standards.

Dietary Supplement Ingredients and Raw Materials 

Here is a partial list of ingredients that we are able to qualify and develop for our clients:

Abies webbiana  (Talispatra)

Abrus precatorius (Rati Gunj)

Acacia arabica (Nilotica)

Acerola Cherry

Achyranthes aspera Seed (Apamarg)

Adhatoda vasica Leaf (Vasa, Adulsa)

Aegle marmelos Fruit (Bilva, Bel)

Aesculus hippocastanum L.

Aglaia roxburghiana Fruit (Priyangu)

Ajmud (Carum roxburgianum)

Allium sativum L.

Aloe ferox Miller

Aloe Gel (Ghrit Kumari)

Aloe vera

Alpha Lipoic Acid

Amalaki, Amla Fruit (Emblica officinalis)

Ambrette Seed (Latakasturi, Muskdana)

Amla Fruit Extract (Phyllanthus emblica)

Amorphophalms konjac

Andrographis Herb (Bhunimba, Kalmegh) Papda)

Andrographis paniculata

Angelica sinensis (Oliv.)Diels

Annatto (Shinduri)


Arctostaphylos uva-ursi L.

Argemone mexicana Herb (Swarnakshiri)

Argyreia nervosa Seed (Vriddhadaru)

Aristolochia indica Root (Pushkarmul)

Arjun Bark (Terminalia arjuna)


Artemisia annua L.

Ascorbic Acid

Ascorbyl Palmitate

Ashok Bark (Saraca indica)

Ashwagandha Root (Withania somnifera)

Asparagus racemosus Root (Shatavari)


Asteracantha longifolia Seed (Talimakhana)

Astragalus membranaceus(Fisch.)Bge

Atibala Root (Abutilon indicum)

Azadiracta indica Bark (Neem)

Azadiracta indica Leaf (Neem)

B-3 Niacinamide USP

Bacopa monnieri Herb (Brahmi)

Bala Root (Sida cordifolia)

Baliospermum montanum (Danti)

Bamboo Manna (Vansrochan)

Barberry Stem Bark

Barley Grass (Yava)

Basil Leaf

Basil Seed (Sabja, Tukmaria)

Basil, Camphor (Karpur Tulsi)

Bauhinia tomentosa Bark (Kanchanar)

Beet Root

Berberis aristata Stem (Daru Haridra/Haldi)

Bergenia ligulata (Pashan Bheda)

Bhringraja Herb (Eclipta alba)

Bhumyamalaki Herb (Phyllanthus amarus)

Bhunimba Herb (Andrographis paniculata)

Bibhitaki, Baheda Fruit (Terminalia bellerica)

Bilberry (Vaccinium myrtillus L.) Fruit

Bilva, Bel Fruit (Aegle marmelos)


Bishops Weed Seed (Ammi majus)

Bitter melon (Karvellak, Karela)

Black Cohosh



Boerhavia diffusa (Punarnava)

Bombax malabaricum (Mochras)

Borago officinalis L. (Borage)

Boswellia serrata (Frankincense, Shallaki)

Brahmi (Bacopa monnieri)

Bridelia retusa (Asana)

Broccoli (Brassica oleracea) Flower Powder

Broccoli Seed Ext BSPE-13-25


Bupleurum Root

Butea monosperma Bark (Palash)

Butea monosperma Flower (Palash)

Buxus sinica( Wils.)Cheng

Caesalpinia bonducella Seed (Lata Karanj)

Caesalpinia sappan (Patang, Sappan wood)

Calamus Root (Vacha, Bach)

Calendula Petals

Calotropis gigantea Root (Mandar, Aak)

Camellia sinensis (L.) O.Kuntze (Green Tea)


Camptotheca acuminata

Cane Sugar

Capsicum annuum L.

Cassia absus (Chakshu)

Cassia angustifolia Vahi

Cassia fistula Fruit Pulp (Arghvadh, Bahava)

Cassia nomame(sibe.)L.Kitagawa

Cassia tora (Chakramard)

Catechu Bark (Khadir, Khair)

Cayenne Pepper Powder

Cedrus deodar Wood (Devdaru)

Celastrus paniculatus Fruit (Jyotismati)

Celery Seed (Apium graveolens, Ajmud)

Centella asiatica (Gotu kola) aerials

Chamomile Herb

Chamomilla recutita(L.)Rausch

Chaste Tree Berry

Chen Pi Extract

Chickweed (Stellaria Media Herb) Extract

Chlorophytum borivilium Root (Safed Musli)

Choline Bitartrate


Cimicifuga foetida L.

Cinnamomum zeylanicum (True or Ceylon cinnamon) bark

Cinnamon (Cinnamomum cassia) bark

Cinnamon Powder Low Oil

Cissampelos pareira (Patha)

Cissus quadrangularis Herb (Ashthisandhar)

Citric Acid Anhydrous USP/FCC

Citrullus colocynthis Fruit (Indravaruni) Citrus anrantium L.

Citrus aurantium L.

Citrus Bioflavonoids

Citrus Bioflavonoids Extract

Citrus paradisi Macfadyen

Clerodendron serratum Root (Bharangi)

Clitoria ternatea Herb (Aparajita)

Cnidium monnieri L.

Coenzyme Q10

Cola nitida(Vent.) Schott et Endl

Coleus barbatus Benth

Coleus forskohlii Root (Pashanbheda)

Commiphora mukul Resin (Guggul)

Commiphora myrrah Resin (Raktabol)

Convolvulus pluricaulis Herb (Shankhpushpi)

Coptis Chinensis Extract

Cordyceps sinensis Extract

Costus speciosus (Kustha)

Country Mallow, Indian Root (Atibala)

Cranberry Fruit Powder

Crataegus pinnatifida

Crataeva nurvala Wood (Vaiverna)

Croscarmellose Sodium

Curculigo orchioides Root (Musli)

Curcuma amada Root (Amra Haridra, Amba Haldi)

Curcuma aromatica (Van Haridra)

Curcuma zedoaria (Karchura)

Curcumin 95% Powder

Curry (Murraya koenigii) Leaf

Cyanocobalamin (Vitamin B12 1%)

Cyanocobalamin 0.1%, Vit B12

Cynara scolymus L

Cynodon dactylon (Durva)

Cyperus rotundus Root (Musta, Nagarmotha)

Datura metel Seed (Dhoorta, Dhatura)

Desmodium gangeticum Root (Shaliparni)

Dioscorea bulbifera Tuber (Varahi Kand)


Dong Quai Extract

Echinacea purpurea Herb Extract

Eclipta alba Herb (Bhringraja)

Eleutherococcus Senticosus Root Extract

Embelia ribes Seed (Vidang)

Emblica officinalis Fruit (Amalaki, Amla)

Epimedium brevicorn

Equisetum arvense L.

Eucalyptus citridora Leaf (Nilgiri)

Euphorbia nerifolia Herb (Sudha)

Evodia rutaecarpa(Juss.)Benth

Evolvulus alsinoides Herb (Shankhpushpi)

Feronia limonia (Wood apple, Kapittha, Kaith)

Ficus benghalensis Bark (Banyan, Vata, Vad)

Ficus benghalensis Shoot (Vatankur)

Ficus racemosa Bark (Udumbara, Gular)

Ficus religiosa Bark (Ashwatha, Peepal)

Flax Seed Extract

Flaxseed Lignans Powder

Foeniculum vulgare Mill (Fennel)

Folic Acid 10%

Folium Artemisiae Argyi

Fructose DC

Fucus vesiculosus L.

Fumaria parviflora Seed (Yavan Parpat, Pitta Papda)

Galangal (Kulinjan)

Ganoderma lucidum (Leyss.ex Fr.)Karst

Garcinia cambogia Fruit Rind (Vrikshamla)

Garcinia mangostana L. (Mangosteen)

Gardenia gummifera (Nadihingu)

Gardenia jasminoides Ellis

Ginger Extract 5%

Ginger Root Powder

Ginkgo Biloba 24% Extract

Gloriosa superba Seed (Langli, Kalihari)

Glucosamine HCl (non-shellfish)

Glycine max(L.)Merr

Glycyrrhiza glabra L.

Gmelina arborea Root (Gambhari, Shivan)

Gokshur Fruit (Tribulus terrestris)

Gokshur Herb (Tribulus terrestris)

Gotu Kola Herb (Mandukparni, Brahmi) Pumpkin Seed

Grape (Citis vinifera) Seed

Green Coffee (Coffea arabica) Bean

Green Tea (Camellia sinensis) Leaf Ext

Green Tea 40% Decaffeinated Water Extracted

Green Tea PE Decaffeinated 40% EGCG

Griffonia Simplicifolia

Guar Gum

Guduchi, Amrita Herb (Tinospora cordifolia)

Guggul Resin (Commiphora mukul)

Gum arabic (Acacia arabica, A. nilotica)

Gymnema Leaf (Madhunashini, Shardunika, Gudmar)

Gymnema sylvestre

Gynostemma pentaphyllum (Thunb.) Makino

Hamamelis mollis Oliver

Haritaki, Harde (Terminalia chebula)

Harpagophytum procumbens DC

Hawthorn Leaf and Flower Ext 5.5 to 1

Hedychium spicatum Root (Sati, Kapur Kachri)

Helicteres isora Fruit (Avartini)

Hemidismus inducus (Anantmul)

Hemsleya amabilis Diels

Hemp Protein

Hemp Seed Oil

Hemp Extract (Cannabidiol, CBD)

Henna Leaf (Madayantika, Mehandi)

Herpestis moniera Herb (Brahmi)


Hibiscus Flower (Japa, Jaswand) Sage

Hippophae rhamnoides L.

Holarrhena antidysenterica Bark (Kutaj)

Holy Basil Leaf (Tulsi)


Hops Extract Powder

Hops Powder

Horse Chestnut Extract  20%

Horsetail Shavegrass

Humulus lupulus L.

Huperzia serrata (Huperzine-A)

Hydrocotyle asiatica Herb (Mandukparni)

Hypericum perforatum L.

Indian Goosebery Fruit (Amalaki, Amla)

Indigo Leaf (Neelini, Neel)



Ipomoea digitata Tuber (Kshri Vidari)

Japanese Knotweed Extract

Jasmine Flower (Mallika)

Jatamansi Root (Nardostachys jatamansi)

Jatropha curcas

Jujube Seed

Kanchanar Bark (Bauhinia tomentosa)

Korean Ginseng (Panax ginseng)

Kutki Root (Picrorhiza kurroa)

Lagerstroemia speciosa (L.) Pers

Laminaria japonica Arsch


Lavandula pedunculata L.

L-Carnitine Fumarate



Lemon Bioflavonoid Complex

Lemon Peel


Lentinus edodes (Berk.)sing

Lepidium sativum Seed

Leptadenia reticulata (Jivanti)


Licorice Extract, Deglycyrrhizinated (Glycyrrhiza Glabra)

Linum usitatissimum L.

Lllicium verum Hook.f

Lotus (Padam, Neel Kamal)


Lycium barbarum L. (Goji berry)

Maca root

Madder, Indian Root (Manjistha)

Madhuca india (Madhuka)

Magnesium Carbonate

Magnesium Gluconate

Magnesium Lactate

Magnolia Bark

Magnolia officinalis Rehd. et Wils


Manganese Gluconate

Marigold Flower (Zendu)


Marshmallow Root Ext 4:1

Melissa officinalis L. (Lemon Balm)

Mentha haplocalyx Briq

Mesua ferra Stamen (Nagkeshara)

Mexican Poppy Herb (Argemon mexicana)

Milk Thistle Seed Extract 80% silymarin

Momordica charantia (Bitter Melon)

Moringa oleifera (Shigru, Sahijan)

Motherwort Powder Extract  6.5:1

Mucuna pruriens

N-Acetyl L-Cysteine

Narcissus pseudonarcissus L.


Nettle Root


Noni (Morinda citrifolia) Fruit

Nyctanthes arbortristis Leaf (Parijat, Harsingar)

Oenothera erythrosepala Borb

Olive Leaf Extract

Opuntia dillenii

Orange Peel

Orange Powder


Oregon Grape Root Extract 4:1

Oroxylum indicum Root (Shyonak, Tetu)

Oroxylum indicum(L.)Vent

Orris, Indian Root (Pushkarmula)

Panax Ginseng Extract

Papaya Leaf


Passion Flower Ext

Patchouli Leaf

Pepper, Long Fruit (Pippali)

Pepper, Long Root (Pippali)

Perilla frutescens(L.)Britt

Perilla Seed Extract

Periwinkle Herb (Sadaphuli)

Phellodendron amurense (Berberine HCl)

Phellodendron amurense Rup

Phosphatyl Serine 30%

Phyllanthus amarus Herb (Bhumyamalaki)

Phyllanthus emblica Fruit (Amalaki, Amla)

Picrorhiza kurroa Root (Katuka, Kutki)

Picrorhiza kurroa Root Extract

Pinus massoniana Lamb

Pinus massoniana Lamb

Piper betle Leaf (Nagvalli, Paan)

Piper Methysticum

Piper nigrum L.

Pistacia integerrima (Karkatshringi)

Plantain Flour

Pluchea lanceolata Root (Rasna)

Plumbago zeylanica Root (Chitrak)

Polygonum cuspidatum Root Extract 50%

Pomegranate Fruit Extract

Pomegranate Flower

Pongamia pinnata (Karanj)

Poppy Seed (Post Dana)

Potassium Sulfate

Potassium bicarbonate

Pregelatinized Starch

Premna integrifolia Root (Agnimantha)

Prune Skin Extract

Psoralea corylifolia Seed (Bakuchi, Bavchi)

Psyllium Husk (Isaphgula, Isabgol)

Pterocarpus marsupium Wood (Vijaysar)

Pueraria lobata (Willd.)

Pueraria Root Extract 40% Isoflavones

Pueraria tuberose Tuber (Vidari)

Pumpkin Seed Powder – Steam Treated

Punarnava Root (Boerhavia diffusa)

Punica granatum L.

Pyridoxine Hydrochloride

Quercetin Anhydrous Granular

Quercetin Anhydrous Powder GRAS

Quercetin Dihydrate

Quercetin Dihydrate Powder

Quercus infectoria (Mayaphal, Majuphal)

Randia dumetorum (Madanphal)

Raspberry Fruit Powder

Rauwolfia serpentine Root (Sarpagandha)

Red Clover Extract

Red Yeast Rice

Rhamnus purshiana

Rhodiola rosea

Rhus succedanea (Karkatshringi)

Riboflavin (Vitamin B2)

Rice Protein Hydrolysate

Rodiola Rosea 5%

Rose Petal (Shatpatri, Gulab)

Rosemary Ext 95%

Rosmarinus officinalis L.


Rubus chingli Hu

Rue Herb (Ruta graveolens)

Ruscus aculeatus L.


Safed Musli Root (Chlorophytum borivilium)

Safflower Seed

Salacia chinesis (Saptarangi)

Salix alba L.

Salvia Extract, 1% Dan Shen

Salvia Sclare L.

Sambucus williamsii Hance

Sappan Wood (Patang)

Saraca indica Bark (Ashok)

Sarperia (Rauwolfia serpentina)

Sarsaparilla, Indian (Anantmul)

Saw Palmetto Ext 45%

Schisandra chinensis(Turcz.)Baill

Scindapsus officinalis (Gajpippli)

Seabuckthorn (Hippophae rhamnoides)


Semecarpus anacardinum Nut (Bhallatak)

Senna Leaf (Markandika, Sanai)

Serenoa repens (Saw palmetto)

Sesame Seed (Til)

Sesamum indicum L.

Shankhpushpi Herb (Convolvulus pluricaulis)

Shatavari Root (Asparagus racemosus)

Sheabutter officinalis

Shorea robusta (Raal)

Sida cordifolia Root (Bala)

Sida rhombifolia Root (Mahabala)

Silybum marianum(L.)gaertn

Sisymbrium officinale L.

Skullcap Root Extract

Soap Nut (Arishtak, Reetha)

Sodium Ascorbate Granular 99%

Sodium Copper Chlorophyllin

Solanum indicum Root (Brihati)

Solanum lycopersicum L

Solanum nigrum Root (Kakmachi)

Solanum xanthocarpum Fruit (Kantakari)

Sophora alopecuroides L.

Sophora japonica L.

Sophora subprostrata

Sorbus aucuparia L.

Soy Isoflavones

Spent Hops (Polyphenol Rich Hops Pellets)

Sphaeranthus indicus Herb (Mundi)

Spikenard, Indian Root (Jatamansi)

Spilanthes acmella Root (Akarkarbha)


St John’s Wort

Stereospermum suaveolens Root (Patala)

Stevia Leaf Extract (Rebaudioside A)

Strychnos potatorum (Nirmali)


Symplocos racemosus Stem (Lodhra)

Syzygium cumini Seed (Jambu, Jamun)

Tagetes erecta L. (Marigold)

Tamarind Fruit

Tamarindus indica L.

Tarragon (Artemisia dracunculus)

Taxus baccata L

Tea, Black

Terminalia arjuna Bark (Arjuna)

Terminalia bellerica Fruit (Bibhitaki, Baheda)

Terminalia chebula Fruit (Haritaki, Harde)

Thiamine Hydrochloride


Thymus mongolicus Ronn

Tinospora cordifolia Stem (Guduchi, Amrita, Galo)

Trachycarpus fortunei(Hook.)H.Wendl)

Tribulus terrestris Fruit (Gokshur, Gokhru)

Trichosanthes cucumerina Root (Patol)

Trifolium pratense L.

Tulsi Leaf (Ocimum sanctum)

Turmeric (Curcuma longa) Root Extract

Turmeric Root Powder

Vaccinium myrtillus L.

Valerian Root ext 0.8%

Valeriana wallichi Root (Sugandha bala, Tagar)

Vanadium Citrate 0.5%

Vanilla Bean

Vasa, Adulsa Leaf (Adhatoda vasica)

Viola odorata Leaf (Banafsa)

Vitex negundo Herb (Nirgundi)

Vitex trifolia L.

Vitis vinifera L.

Voacango africana Stapf

Watercress Herb Ext. 4:1 Steam Treated (non irradiated)

Wheat Grass

White Willow Bark 15%

Withania somnifera (Ashwagandha)

Wormwood Plant Ext 5%, 8:1

Xylitol (Foods)

Zanthoxylum bungeanum Maxim

Zinc Chelate (Tasteless) 10%

Zinc Citrate 32%

Zingiber officinale Roscoe (Ginger) root

Ziziphus jujube

Here are ingredient of concern listed on FDA’s website:

Dietary Supplement Testing and Analysis: Quality Control

by NaturPro in Uncategorized Comments: 0

Dietary Supplement Testing and Analysis: Quality Control

Dietary supplements are subject to FDA requirements for good manufacturing practices (cGMP) and quality control in the United States. cGMP require specifications for each ingredient and finished dietary supplement. The specifications list parameters for identity, purity, potency and other requirements for regulatory compliance. Each parameter on the specification must be tested with a scientifically valid method.

NaturPro Scientific, as an UnLab, partners with expert analytical laboratories to conduct specific testing on dietary supplements. Testing typically includes:

  • Physical characteristics (visual, color, odor, taste, density, mesh size)
  • Identity (matching an ingredient in a pass/fail fashion to a particular species of botanical or herb, or a chemical purity test)
  • Potency (concentration of active or marker compounds)
  • Purity (absence of impurities such as moisture, microbiology, pathogens, heavy metals, residual solvents, pesticides, mycotoxins)

The following are analytical principles or instruments that may be used for dietary supplement testing:

  • Karl Fischer
  • Ro-tap and particle size analysis
  • Titration
  • Gravimetry
  • Thin Layer Chromatography (TLC or HP-TLC)
  • High Performance Liquid Chromatography (HPLC)
  • Gas Chromatography with Flame Ionization Detection (GC-FID)
  • Gas Chromatography with Mass Spectrometry (GC-MS of GC-MS-MS)
  • Inductively Coupled Plasma Mass Spectrometry (ICP-MS)
  • Total Aerobic Plate Count
  • Pathogens (Salmonella, E. Coli, Staph)

The following is a list of documentation and regulations requiring testing under cGMPs:

  • Documentation of the specifications established (21 CFR 111.95(b)(1))
  • Documentation of your qualification of a supplier for the purpose of relying on the supplier’s certificate of analysis (21 CFR 111.95(b)(2))
  • Documentation for why meeting in-process specifications, in combination with meeting component specifications, helps ensure that the dietary supplement meets the specifications for identity, purity, strength, and composition; and for limits on those types of contamination that may adulterate or may lead to adulteration of the finished batch of the dietary supplement (21 CFR 111.95(b)(3))
  • Documentation for why the results of appropriate tests or examinations for the product specifications that you selected for testing ensure that the dietary supplement meets all product specifications (21 CFR 111.95(b)(4))
  • Documentation for why any component and in-process testing, examination, or monitoring, and any other information, will ensure that a product specification that is exempted under 21 CFR 111.75(d) is met without verification through periodic testing of the finished batch, including documentation that the selected specifications tested or examined under 21 CFR 111.75 (c)(1) are not able to verify that the production and process control system is producing a dietary supplement that meets the exempted product specification and there is no scientifically valid method for testing or examining such exempted product specification at the finished batch stage (21 CFR 111.95(b)(5))

There are a number of sources of information for developing specifications and test methods for analysis of dietary supplements. The below is a partial list of references and resources:

  1. Dietary Supplement Ingredient Database,
  2. Dietary Supplement Label Database,
  3. Dietary supplement laboratory quality assurance program: the first five exercises. Phillips MM, Rimmer CA, Wood LJ, Lippa KA, Sharpless KE, Duewer DL, Sander LC, Betz JM.  J AOAC Int 2011;94:803-14.
  4. Heavy metals: analysis and limits in herbal dietary supplements,
  5. Pesticide Analytical Manual, Vol I, FDA. Source:
  6. Pesticide Analytical Manual, Vol II, FDA. Source:
  7. Quality assurance of cultivated and gathered medicinal plants. Mathe and Mathe, Source:
  8. Quality control methods for medicinal plant materials (1998) World Health Organization
  9. Recommendations for microbial limits in herbal products, American Herbal Products Association,
  10. Standardization of herbal medicines – A review. Kunle O.F. et al, (2012) Int. J Biodiv and Conserv. 4(3) 101-112. Source:
  11. USP Food Fraud Mitigation Guidance,


Nootropic Supplement Product Development

Development of nootropic supplements as products supporting brain and cognitive health requires a focus on efficacy, quality and purity. Regulatory compliance and safety of ingredients for nootropics are key factors in developing formulas and products.

Facts on Nootropic Supplement Product Development:

  1. NaturPro Scientific assists in the development, sourcing, testing and production of nootropic ingredients and products.
  2. Focus, attention, memory and alertness are all clinical endpoints measured for nootropics.
  3. Nootropics may come in the form of capsules, powders, beverages, tea bags, tablets, liquids and even foods.
  4. Caffeine is one of the most widely consumed nootropics.
  5. Here’s an example of a proprietary Nootropic Tea Formula or NooTea.

What are Nootropics?

From Wikipedia:

Nootropics (pronunciation: /n.əˈtrɒpks/ noh-ə-trop-iks)—also called smart drugs or cognitive enhancers—are drugs, supplements, or other substances that improve cognitive function, particularly executive functions, memory, creativity, or motivation, in healthy individuals.[1][2] The use of cognition-enhancing drugs by healthy individuals in the absence of a medical indication is one of the most debated topics among neuroscientists, psychiatrists, and physicians which spans a number of issues, including the ethics and fairness of their use, concerns over adverse effects, and the diversion of prescription drugs for nonmedical uses, among others.[1][3][4] Nonetheless, the international sales of cognition-enhancing supplements exceeded US$1 billion in 2015 and the global demand for these compounds is still growing rapidly.[5]

The word nootropic was coined in 1972 by a Romanian psychologist and chemist, Corneliu E. Giurgea,[6][7] from the Greek words νους (nous), or “mind”, and τρέπειν (trepein), meaning to bend or turn.[8]

Nootropic Safety and Side Effects

Many ingredients used in nootropic supplements are synthetic substances not found in nature or our food supply. These may be considered unapproved drugs. Central nervous system stimulants and plant alkaloids are also areas of concern for safety, due to their impact on the brain. Many CNS stimulants are considered toxic to the liver and other organs. It is essential that nootropic ingredients are supported by safety studies and a long history of human use, in addition to GRAS (generally recognized as safe) or other suitable safety assessments as determined by regulations.

From Wikipedia: “The main concern with pharmaceutical drugs is adverse effects, and these concerns apply to cognitive-enhancing drugs as well. Long-term safety data is typically unavailable for some types of nootropics[9] (e.g., many non-pharmaceutical cognitive enhancers, newly developed pharmaceuticals and pharmaceuticals with short-term therapeutic use). Racetams—piracetam and other compounds that are structurally related to piracetam—have few serious adverse effects and low toxicity, but there is little evidence that they enhance cognition in individuals without cognitive impairments.[22][23] While addiction to stimulants is sometimes identified as a cause for concern,[24] a very large body of research on the therapeutic use of the “more addictive” psychostimulants indicate that addiction is fairly rare in therapeutic doses.[25][26][27] On their safety profile, a systematic review from June 2015 asserted, “evidence indicates that at low, clinically relevant doses, psychostimulants are devoid of the behavioral and neurochemical actions that define this class of drugs and instead act largely as cognitive enhancers.”[28]

In the United States dietary supplements may be marketed if the manufacturer can show that it can manufacture the supplement safely, that the supplement is indeed generally recognized as safe, and if the manufacturer does not make any claims about the supplement’s use to treat or prevent any disease or condition; supplements that contain drugs or for which treatment or prevention claims are made are illegal under US law.”

Types of Nootropics (From Wikipedia):



  • l-Theanine – A 2014 systematic review and meta-analysis found that concurrent caffeine and l-theanine use has synergistic psychoactive effects that promote alertness, attention, and task switching;[43] these effects are most pronounced during the first hour post-dose.[43]
  • Tolcapone – a systematic review noted that it improves verbal episodic memory and episodic memory encoding.[44]
  • Levodopa – a systematic review noted that it improves verbal episodic memory and episodic memory encoding.[44]
  • Atomoxetine – can improve working memory and aspects of attention when used at an optimal dose.[33]

Dietary supplements

  • Bacopa monnieri – A herb sold as a dietary supplement. There is some preliminary evidence for memory-enhancing effects.[45]
  • Panax ginseng – A review by the Cochrane Collaboration concluded that “there is a lack of convincing evidence to show a cognitive enhancing effect of Panax ginseng in healthy participants and no high quality evidence about its efficacy in patients with dementia.”[46] According to the National Center for Complementary and Integrative Health “Although Asian ginseng has been widely studied for a variety of uses, research results to date do not conclusively support health claims associated with the herb.”[47] According to a review published in the journal “Advances in Nutrition”, multiple RCTs in healthy volunteers have indicated increases in accuracy of memory, speed in performing attention tasks and improvement in performing difficult mental arithmetic tasks, as well as reduction in fatigue and improvement in mood.[48]
  • Ginkgo biloba – An extract of Ginkgo biloba leaf (GBE) is marketed in dietary supplement form with claims it can enhance cognitive function in people without known cognitive problems. Studies have failed to find such effects on memory or attention in healthy people.[49][50]


Racetams, such as piracetam, oxiracetam, and aniracetam, are structurally similar compounds, which are often marketed as cognitive enhancers and sold over-the-counter. Racetams are often referred to as nootropics, but this property of the drug class is not well established.[51] The racetams have poorly understood mechanisms of action; however, piracetam and aniracetam are known to act as positive allosteric modulators of AMPA receptors and appear to modulate cholinergic systems.[52]

According to the US Food and Drug Administration, “Piracetam is not a vitamin, mineral, amino acid, herb or other botanical, or dietary substance for use by man to supplement the diet by increasing the total dietary intake. Further, piracetam is not a concentrate, metabolite, constituent, extract or combination of any such dietary ingredient. […] Accordingly, these products are drugs, under section 201(g)(1)(C) of the Act, 21 U.S.C. § 321(g)(1)(C), because they are not foods and they are intended to affect the structure or any function of the body. Moreover, these products are new drugs as defined by section 201(p) of the Act, 21 U.S.C. § 321(p), because they are not generally recognized as safe and effective for use under the conditions prescribed, recommended, or suggested in their labeling.”[53]

Null findings in systematic reviews

  • Omega-3 fatty acids: DHA and EPA – two Cochrane Collaboration reviews on the use of supplemental omega-3 fatty acids for ADHD and learning disorders conclude that there is limited evidence of treatment benefits for either disorder.[54][55] Two other systematic reviews noted no cognition-enhancing effects in the general population or middle-aged and older adults.[56][57]
  • B vitamins – no cognition-enhancing effects in middle-aged and older adults.[57]
  • Vitamin E – no cognition-enhancing effects in middle-aged and older adults.[57]
  • Pramipexole – no significant cognition-enhancing effects in healthy individuals.[44]
  • Guanfacine – no significant cognition-enhancing effects in healthy individuals.[44]
  • Clonidine – no significant cognition-enhancing effects in healthy individuals.[44]
  • Ampakines – no significant cognition-enhancing effects in healthy individuals.[44]
  • Fexofenadine – no significant cognition-enhancing effects in healthy individuals.[44]
  • Salvia officinalis – Although some evidence is suggestive of cognition benefits, the study quality is so poor that no conclusions can be drawn from it.[58]

Turmeric Supplement Testing — Curcumin Products

by NaturPro in Uncategorized Comments: 0

Laboratory testing of turmeric supplements and curcumin products is important for quality, safety, dosage and bioavailability. NaturPro Scientific offers testing and analysis consulting for turmeric, and works with expert research and quality control testing laboratories.

A number of analytical methods and monographs have been developed for turmeric to ensure bioavailability, consistency, potency and purity of curcumin products.

Turmeric Supplement Testing — Curcumin Products

We recommend all turmeric products have routine and/or periodic independent testing for the following parameters:

  1. Curcuminoids (curcumin) by HPLC
  2. Biological activity
  3. Bioavailability
  4. Heavy metals
  5. Microbiology and pathogens
  6. Residual solvents
  7. Pesticides
  8. Natural source by carbon radioisotope (if labeled as ‘turmeric’)
  9. Food allergens
  10. Sudan dyes

Traditional dosage forms listed by the EU Community Herbal Monograph include the following herbal preparations:

  1. Powdered herbal substance
  2. Comminuted herbal substance
  3. Tincture (Ratio of herbal substance to extraction solvent 1:10), extraction solvent ethanol 70% (v/v)
  4. Dry extract (DER 13-25:1), extraction solvent ethanol 96% (v/v)
  5. Dry extract (DER 5.5-6.5:1), extraction solvent ethanol 50% (v/v)
  6. Tincture (Ratio of herbal substance to extraction solvent 1:5), extraction solvent ethanol 70% (v/v)
    Other solvents are commonly used to extract curcuminoids.

The JECFA has developed a monograph on turmeric oleoresin:

“Obtained by solvent extraction of turmeric (Curcuma longa L.). Only the following solvents may be used in the extraction: acetone, dichloromethane, 1,2-dichloroethane, methanol, ethanol, isopropanol and light petroleum (hexanes).

The selection of a turmeric oleoresin of a particular composition is based on the intended use in food. In general, all turmeric oleoresins contain colouring matter and most contain flavouring matter but some oleoresins are processed to remove aromatic compounds. Commercial products include oleoresins (per se) and formulations in which oleoresin is diluted in carrier solvents and which may contain emulsifiers and antioxidants. Purified extracts of turmeric containing more than 90% total colouring matter are subject to specifications for “Curcumin”.

Turmeric Oleoresins are sold on the basis of “colour value” or “curcumin content”, which generally means the total content of the curcuminoid substances: (I) curcumin, (II) demethoxycurcumin and (III) bis- demethoxycurcumin.

The principle colouring components are:
I. 1,7-Bis(4-hydroxy-3-methoxyphenyl)hepta-1,6-diene- 3,5-dione
II. 1-(4-Hydroxyphenyl)-7-(4-hydroxy-3-methoxyphenyl)-hepta-1,6-diene- 3,5-dione
III. 1,7-bis(4-hydroxyphenyl)hepta-1,6-diene-3,5-dione

Turmeric Oleoresins, per se, are deep brownish-orange viscous oily fluids, pasty semisolids or hard amorphous solids containing 37-55% curcuminoids and up to 25% volatile oil. Diluted turmeric oleoresin formulations are, generally yellow solutions containing 6-15% curcuminoids and nil to 10% volatile oil.

Residual solvents limits:

Acetone : Not more than 30 mg/kg
Methanol: Not more than 50 mg/kg
Ethanol: Not more than 50 mg/kg
Isopropanol: Not more than 50 mg/kg
Dichloromethane and 1,2-dichloroethane: Not more than 30 mg/kg, singly or in combination

Light petroleum (hexanes): Not more than 25 mg/kg

The WHO monograph for medicinal plants for turmeric is excerpted below:

Rhizome (root) of Curcuma Longa L. (turmeric)


Rhizoma Curcumae Longae is the dried rhizome of Curcuma longa L. (Zingiberaceae) (1).

Dried rhizomes of Curcuma wenyujin Y.H. Lee et C. Ling, C. kwangsiensis S. Lee et C.F. Liang. and C. phaeocaulis Val. are also official sources of Radix Curcumae or Turmeric Root-Tuber in China (2).


Curcuma domestica Valeton., C. rotunda L., C. xanthorrhiza Naves, Amomum curcuma Jacq. (3–5).

Selected vernacular names

Acafrao, arqussofar, asabi-e-safr, avea, cago rerega, chiang-huang, common tumeric, curcum, curcuma, dilau, dilaw, Gelbwurzel, gezo, goeratji, haladi, haldi, haldu, haku halu, hardi, haridra, huang chiang, hsanwen, hurid, Indian saffron, jiânghuang, kaha, kakoenji, kalo haledo, khamin chan, khaminchan, kilunga kuku, kitambwe, kiko eea, koening, koenit, koenjet, kondin, kooneit, kunyit, kurcum, kurkum, Kurkumawurzelstock, luyang dilaw, mandano, manjano, manjal, nghe, nisha, oendre, pasupu, rajani, rame, renga, rhizome de curcuma, saffran vert, safran, safran des indes, skyer-rtsa, tumeric, tumeric root, tumeric rhizome, turmeric, ukon, ul gum, wong keong, wong keung, yellow root, yii-chin, zardchob (13, 6–14).


Perennial herb up to 1.0 m in height; stout, fleshy, main rhizome nearly ovoid (about 3 cm in diameter and 4 cm long). Lateral rhizome, slightly bent (1cm × 2–6cm), flesh orange in colour; large leaves lanceolate, uniformly green, up to 50cm long and 7–25cm wide; apex acute and caudate with tapering base, petiole and sheath sparsely to densely pubescent. Spike, apical, cylindrical, 10– 15cm long and 5–7 cm in diameter. Bract white or white with light green upper half, 5–6 cm long, each subtending flowers, bracteoles up to 3.5 cm long. Pale yellow flowers about 5cm long; calyx tubular, unilaterally split, unequally toothed; corolla white, tube funnel shaped, limb 3-lobed. Stamens lateral, petaloid, widely elliptical, longer than the anther; filament united to anther about the middle of the pollen sac, spurred at base. Ovary trilocular; style glabrous. Capsule ellipsoid. Rhizomes orange within (1, 4, 6, 15).

Plant material of interest: dried rhizome

General appearance

The primary rhizome is ovate, oblong or pear-shaped round turmeric, while the secondary rhizome is often short-branched long turmeric; the round form is about half as broad as long; the long form is from 2–5cm long and 1–1.8cm thick; externally yellowish to yellowish brown, with root scars and annulations, the latter from the scars of leaf bases; fracture horny; internally orangeyellow to orange; waxy, showing a cortex separated from a central cylinder by a distinct endodermis (1, 9, 13).

Organoleptic properties

Odour, aromatic; taste, warmly aromatic and bitter (1, 9, 13). Drug when chewed colours the saliva yellow (9).

Microscopic characteristics

The transverse section of the rhizome is characterized by the presence of mostly thin-walled rounded parenchyma cells, scattered vascular bundles, defi- nite endodermis, a few layers of cork developed under the epidermis and scattered oleoresin cells with brownish contents. The cells of the ground tissue are also filled with many starch grains. Epidermis is thin walled, consisting of cubical cells of various dimensions. The cork cambium is developed from the subepidermal layers and even after the development of the cork, the epidermis is retained. Cork is generally composed of 4–6 layers of thin-walled brickshaped parenchymatous cells. The parenchyma of the pith and cortex contains curcumin and is filled with starch grains. Cortical vascular bundles are scattered and are of collateral type. The vascular bundles in the pith region are mostly scattered and they form discontinuous rings just under the endodermis. The vessels have mainly spiral thickening and only a few have reticulate and annular structure (1, 8, 9).

Powdered plant material

Coloured deep yellow. Fragments of parenchymatous cells contain numerous altered, pasty masses of starch grains coloured yellow by curcumin, fragments of vessels; cork fragments of cells in sectional view; scattered unicellular trichomes; abundant starch grains; fragments of epidermal and cork cells in surface view; and scattered oil droplets, rarely seen (1, 13).

Geographical distribution

Cambodia, China, India, Indonesia, Lao People’s Democratic Republic, Madagascar, Malaysia, the Philippines, and Viet Nam (1, 13, 16). It is exten- sively cultivated in China, India, Indonesia, Thailand and throughout the tropics, including tropical regions of Africa (1, 7, 13, 16).

General identity tests

Macroscopic and microscopic examinations; test for the presence of curcuminoids by colorimetric and thin-layer chromatographic methods (1).

Purity tests


The test for Salmonella spp. in Rhizoma Curcumae Longae products should be negative. The maximum acceptable limits of other microorganisms are as follows (17–19). For preparation of decoction: aerobic bacteria-not more than 107/g; fungi-not more than 105/g; Escherichia coli-not more than 102/g. Preparations for internal use: aerobic bacteria-not more than 105/g or ml; fungi-not more than 104/g or ml; enterobacteria and certain Gram-negative bacteria-not more than 103/g or ml; Escherichia coli-0/g or ml.

Foreign organic matter

Not more than 2% (1, 9).

Total ash

Not more than 8.0% (1, 15).

Acid-insoluble ash

Not more than 1% (1, 9, 15).

Water-soluble extractive

Not less than 9.0% (1).

Alcohol-soluble extractive

Not less than 10% (1).


Not more than 10% (1).

Pesticide residues

To be established in accordance with national requirements. Normally, the maximum residue limit of aldrin and dieldrin in Rhizoma Curcumae Longae is not more than 0.05 mg/kg (19). For other pesticides, see WHO guidelines on quality control methods for medicinal plants (17) and guidelines for predicting dietary intake of pesticide residues (20).

Heavy metals

Recommended lead and cadmium levels are not more than 10 and 0.3mg/kg, respectively, in the final dosage form of the plant material (17).

Radioactive residues

For analysis of strontium-90, iodine-131, caesium-134, caesium-137, and plutonium-239, see WHO guidelines on quality control methods for medicinal plants (17).

Other purity tests

Chemical tests to be established in accordance with national requirements.

Chemical assays

Not less than 4.0% of volatile oil, and not less than 3.0% of curcuminoids (1). Qualitative analysis by thin-layer and high-performance liquid chromatography (1, 21) and quantitative assay for total curcuminoids by spectrophotometric (1, 22) or by high-performance liquid chromatographic methods (23, 24).

Major chemical constituents

Pale yellow to orange-yellow volatile oil (6%) composed of a number of monoterpenes and sesquiterpenes, including zingiberene, curcumene, α- and β- turmerone among others. The colouring principles (5%) are curcuminoids, 50–60% of which are a mixture of curcumin, monodesmethoxycurcumin and bisdesmethoxycurcumin (1, 6, 25). Representative structures of curcuminoids are presented below.

Dosage forms

Powdered crude plant material, rhizomes (1, 2), and corresponding preparations (25). Store in a dry environment protected from light. Air dry the crude drug every 2–3 months (1).

Medicinal uses

Uses supported by clinical data

The principal use of Rhizoma Curcumae Longae is for the treatment of acid, flatulent, or atonic dyspepsia (26–28).

Uses described in pharmacopoeias and in traditional systems of medicine

Treatment of peptic ulcers, and pain and inflammation due to rheumatoid arthritis (2, 11, 14, 29, 30) and of amenorrhoea, dysmenorrhoea, diarrhoea, epilepsy, pain, and skin diseases (2, 3, 16).

Uses described in folk medicine, not supported by experimental or clinical data

The treatment of asthma, boils, bruises, coughs, dizziness, epilepsy, haemorrhages, insect bites, jaundice, ringworm, urinary calculi, and slow lactation (3, 7, 8–10, 14).




Echinacea Supplement Testing — Echinacea purpurea, E. angustifolia

by NaturPro in Uncategorized Comments: 0

Echinacea Supplement Testing — Echinacea purpurea, E. angustifolia

Echinacea testing is critical to determining the quality, identity and potency of an echinacea material. NaturPro Scientific offers testing consulting for echinacea supplements.

Echinacea analysis and testing is based mainly on the WHO  monograph on Echinacea that is excerpted in part below, and the USP monograph.


Herba Echinaceae Purpureae


Herba Echinaceae Purpureae consists of the fresh or dried aerial parts of Echinacea purpurea (L.) Moench harvested in full bloom (Asteraceae) (1).


Brauneria purpurea (L.) Britt., Echinacea intermedia Lindl., E. purpurea (L.) Moench f., E. purpurea (L.) Moench var. arkansana Steyerm., E. speciosa Paxt., Rudbeckia purpurea L., R. hispida Hoffm., R. serotina Sweet (2, 3).

Asteraceae are also known as Compositae.

Selected vernacular names

Coneflower, purple coneflower herb, purpurfarbener Igelkopf, purpurfarbene Kegelblume, purpurfarbener Sonnenhut, red sunflower, roter Sonnenhut (48).


A hardy, herbaceous perennial. Stems erect, stout, branched, hirsute or glabrous, 60–180 cm high; basal leaves ovate to ovate-lanceolate, acute, coarsely or sharply serrate, petioles up to 25 cm long, blades to 20 cm long and 15cm wide, blade abruptly narrowing to base, often cordate, decurrent on petiole, 3–5 veined; cauline leaves petiolate below, sessile above, 7–20 cm long, 1.5–8cm broad, coarsely serrate to entire, rough to the touch on both surfaces; phyllaries linear-lanceolate, attenuate, entire, pubescent on outer surface, ciliate, passing into the chaff; heads 1.5–3cm long and 5–10mm broad, purplish; pales 9– 13mm long, awn half as long as body; disc corollas 4.5–5.5mm long, lobes 1mm long; achene 4–4.5 mm long, pappus a low crown of equal teeth; pollen grains yellow, 19–21µm in diameter; haploid chromosome number n = 11 (2).

Plant material of interest: fresh or dried aerial parts

General appearance

The macroscopic characteristics of Herba Echinaceae Purpureae are as described above under Description. An abbreviated description is currently unavailable.

Organoleptic properties

Mild, aromatic odour; initially sweet taste that quickly becomes bitter.

Microscopic characteristics

A description of the microscopic characteristics of a cross-section of the aerial parts of the plant is currently unavailable.

Powdered plant material

A description of the powdered plant material is currently unavailable.

Geographical distribution

Echinacea purpurea is native to the Atlantic drainage area of the United States of America and Canada, but not Mexico. Its distribution centres are in Arkansas, Kansas, Missouri, and Oklahoma in the United States of America (2). Echinacea purpurea has been introduced as a cultivated medicinal plant in parts of north and eastern Africa and in Europe (9).

General identity tests

Macroscopic examination (2) and thin-layer chromatography and highperformance liquid chromatography (4, 10–13) of the lipophilic constituents and chicoric acid in methanol extracts.

Purity tests


The test for Salmonella spp. in Herba Echinaceae Purpureae should be negative. The maximum acceptable limits of other microorganisms are as follows (1416). For preparation of decoction: aerobic bacteria-not more than 107/g; fungi-not more than 105/g; Escherichia coli-not more than 102/g. Preparations for internal use: aerobic bacteria-not more than 105/g or ml; fungi-not more than 104/g or ml; enterobacteria and certain Gram-negative bacteria-not more than 103/g or ml; Escherichia coli-0/g or ml. Preparations for external use: aerobic bacteria-not more than 102/g or ml; fungi-not more than 102/g or ml; enterobacteria and certain Gram-negative bacteria-not more than 101/g or ml.

Pesticide residues

To be established in accordance with national requirements. Normally, the maximum residue limit of aldrin and dieldrin in Herba Echinaceae Purpureae is not more than 0.05 mg/kg (16). For other pesticides, see WHO guidelines on quality control methods for medicinal plants (14) and guidelines for predicting dietary intake of pesticide residues (17).

Heavy metals

Recommended lead and cadmium levels are no more than 10 and 0.3mg/kg, respectively, in the final dosage form of the plant material (14).

Radioactive residues

For analysis of strontium-90, iodine-131, caesium-134, caesium-137, and plutonium-239, see WHO guidelines on quality control methods for medicinal plants (14).

Other purity tests

Chemical tests and tests for acid-insoluble ash, dilute ethanol-soluble extractive, foreign organic matter, moisture, total ash, and water-soluble extractive to be established in accordance with national requirements.

Chemical assays

For essential oil (0.08–0.32%); chicoric acid (1.2–3.1%) (4). Quantitative analysis of echinacoside, chicoric acid, isobutylamides, and other constituents by high-performance liquid chromatography (4). Quantitative analysis of alkamides and caffeic acid derivatives by thin-layer chromatography and highperformance liquid chromatography (4, 12).

Major chemical constituents

A number of chemical entities have been identified, including alkamides, polyalkenes, polyalkynes, caffeic acid derivatives, and polysaccharides (3, 5–9).

The volatile oil contains, among other compounds, borneol, bornyl acetate, pentadeca-8-(Z)-en-2-one, germacrene D, caryophyllene, and caryophyllene epoxide.

Isobutylamides of C11–C16 straight-chain fatty acids with olefinic or acetylenic bonds (or both) are found in the aerial parts of Herba Echinaceae Purpureae, with the isomeric dodeca-(2E,4E,8Z,10E/Z)-tetraenoic acid isobutylamides.

The caffeic acid ester derivative chicoric acid is the major active compound of this class found in the aerial parts of Echinacea purpurea, with a concentration range of 1.2–3.1%. Chicoric acid methyl ester and other derivatives are also present.

Polysaccharide constituents from Herba Echinaceae Purpureae are of two types: a heteroxylan of average relative molecular mass about 35 000 (e.g. PS-I), and an arabinorhamnogalactan of average relative molecular mass about 45000 (e.g. PS-II).

Other constituents include trace amounts of pyrrolizidine alkaloids (tussilagine (0.006%) and isotussilagine). At these concentrations, the alkaloids are considered to be non-toxic (8). Furthermore, because these alkaloids lack the 1,2-unsaturated necine ring of alkaloids such as senecionine (structure in box) from Senecio species, they are considered to be non-hepatotoxic (3).

Dosage forms

Powdered aerial part, pressed juice and galenic preparations thereof for internal and external use (1, 3).

Medicinal uses

Uses supported by clinical data

Herba Echinaceae Purpureae is administered orally in supportive therapy for colds and infections of the respiratory and urinary tract (1, 3, 5, 7, 8, 18). Beneficial effects in the treatment of these infections are generally thought to be brought about by stimulation of the immune response (3, 5, 7). External uses include promotion of wound healing and treatment of inflammatory skin conditions (1, 3, 5, 7, 8, 9, 19).

Uses described in pharmacopoeias and in traditional systems of medicine


Uses described in folk medicine, not supported by experimental or clinical data

Other medical uses claimed for Herba Echinaceae Purpureae include treatment of yeast infections, side-effects of radiation therapy, rheumatoid arthritis, blood poisoning, and food poisoning (1, 5, 7, 9).

The following summarizes some current methods for identifying  from a published review on echinacea:

“Alkamides, caffeic acid derivatives, and polysaccharides have been considered important constituents of the plant. A number of studies revealed that alkamides are involved in the immunomodulatory properties of Echinacea extracts in vitroand in vivo.[4,5] Additionally, caffeic acid is found in some species of Echinacea and could be applied toward authentication and quality control of the plant extracts. The polysaccharides play an important role in the anti-inflammatory effect of Echinacea preparations.[6] Taxonomic, chemical, pharmacological, and clinical characteristics of some species of the Echinacea genus including E. angustifolia, E. pallida, and E. purpurea were reviewed in previous papers.[1,7] Medicinal properties of the plant were also considered in a review paper, which suggested that more research is required for more definitive medicinal recommendations.[8] This paper is a review about E. purpurea: Its phytochemical contents and its pharmacological and biological activities, along with common methods of plant extract analysis. In addition, the psychoactive and mosquitocidal effects of the plant are mentioned in this paper….

Alkamides have been analyzed with reverse-phase HPLC coupled with different detectors including UV spectrophotometric, coulometric electrochemical, and electrospray ionization mass spectrometric.[83,84] Furthermore, caffeic acid derivatives have been determined using reverse-phase HPLC or capillary electrophoresis (CE) with photodiode array (FDA) UV spectrophotometric detection.[85,86,87] Phenolic acids were analyzed by micellar benzoic acid electrokinetic chromatography (MEKC), both charged and uncharged analytes, based on the use of sodium deoxycholate (SDC), a surfactant in borate buffer (pH 9.2), as well as in the E. purpurea extract.[88] However, determination methods for both caffeic acid derivatives and alkamides have been developed in single analysis. Although it is a difficult process to separate these diverse constituents in one analysis, methods for the concurrent determination of caffeic acid derivatives and alkamides have the advantages of reduced time and sample size needed for the analysis.[85] Gradient elution on reverse-phase HPLC has been employed for concurrent analysis of caffeic acid derivatives and alkamides from E. purpurea using various detectors such as FDA UV spectrophotometric and electrospray ionization mass spectrometry (EIMS).[79,85] Simultaneous analysis of both mentioned derivatives has also been performed by electrophoresis with FDA UV spectrophotometric detector, together with sodium dodecyl sulfate and hydroxypropyl-β-cyclodextrin in Britton Robinson buffer (10 mM, pH 8.0).[89]”

Source: Pharmacogn Rev. 2015 Jan-Jun; 9(17): 63–72 (