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Supplement & Distributor SOP’s and Procedures


If you market your own label of supplement or food product that is manufactured by a third party, such as a contract manufacturer or copacker, then you are responsible for its manufacture and labeling—even if you never physically touch the product. 

Good Manufacturing Practices GMP for Dietary Supplements

Marketers and Private Label sellers and distributors of supplements are required to have several procedures and SOP’s to ensure you are meeting FDA GMP (Good Manufacturing Practices) requirements. Some of the areas every supplement product marketer needs to have and follow, include controls and review of labels and packaging, compliance marketing, websites, web pages and health claims, product registration, quality policies, handling complaints and adverse event reports, and safety procedures.

Below is a partial list of SOP’s and standard operating procedures, policies and protocols that every own-label distributor and brand marketer in the supplement industry should consider having in order to meet FDA GMP requirements.

Dietary Supplement Ingredient Quality Assurance

  1. Supplier Qualification, Manufacturer, Copacker and Vendor Qualification
    1. Supplier Audits and Inspections (Virtual Inspections, In-person Audits)
    2. Contract Manufacturer and Packager Qualification
    3. Contract Laboratory Qualification
    4. Purchasing Requirements
  2. Registering Product in Your Country/State
    1. Import / Export Requirements
  3. New Product Development
    1. Outline of Stage Gates and Review Process, Timeline 
    2. Regulatory and Food Safety Review
  4. Marketing and Claims Review
    1. Label Development, Review and Approval
    2. Website and Marketing Copywriting Review
    3. Claims Substantiation Policy
  5. Communications Policies
    1. Social Media and Customer Service for Product and Health Claims
    2. Email and Social Media Policy
    3. Confidentiality Policy and Non-Disclosure Agreements
  6. Personnel
    1. Employee Training Program 
    2. Personnel Responsibilities / Job Descriptions
    3. Employee Qualifications
    4. Personnel Health and Hygiene 
    5. Employee Safety
    6. Emergency Response & Crisis Management
    7. Handling Worker Injury
  7. Product Quality Policy
    1. Authorities and Responsibilities of the Quality Unit
    2. Preventing Adulteration & Sabotage
    3. Product Testing
    4. Testing Lab Qualification
    5. Product Inspection
    6. Product Approval and Release
    7. Specifications and Certificates of Analysis
    8. Material Review and Disposition (Decision)
    9. Out of Specification (OOS) Investigation
    10. Representative and Reserve Samples
  8. Traceability
    1. Inventory Control
  9. Complaints Handling
    1. Adverse Event Handling (including Serious Adverse Event reporting)
    2. Internal Complaint Handling / Employee Happiness
  10. Recordkeeping
    1. Document Management 
    2. Electronic Records and Electronic Signatures
  11. Facility Management
    1. Pest Control 
    2. Warehouse Operations 
  12. Transportation of Product 
  13. Returned Goods 
  14. Product Recall 
  15. Regulatory Inspections

Good Manufacturing Practices GMP

Contact us to discuss your needs as a distributor, marketer or seller of dietary supplements and healthy foods, and ensure compliance with FDA GMP’s.

Finding success in the RTD beverage aisle


Dietary Supplement Product Experts

While learning from success is seemingly more enjoyable, there are lessons to be learned in failure as well. Learn the top tips for success and avoiding failure in the RTD beverage aisle. 

Blake Ebersole | Sep 17, 2020

First published in Natural Products Insider

Insider Takes

  • The RTD beverage aisle in closeout stores provides valuable intel regarding product launch failures.
  • World circumstances have led to great opportunities for enjoyable, affordable functional beverages.
  • Brands should focus on creating a unique value proposition versus struggling to find a new ingredient.

Everyone likes to emulate and learn from the success stories in product development—the ones that made it big and struck it rich. But learning from failure is important, too. Because for every success story in ready-to-drink (RTD) beverages, a dozen struggled to turn a profit. In the internet age, products developed with great fanfare all too often disappear into oblivion within a couple years. And whatever happened to (insert the name of that drink)? Fortunately, there’s a place to see what’s ready to fall off the edge of the world.

In almost every decent-sized town and city, a closeout grocery market offers expired and overstock goods that couldn’t be sold in the primary markets. The RTD beverage aisle in closeout stores is prominent, due to its large size and great selection of drinks that no one else wanted when they were fresh. I call it the aisle of failure. This place is fascinating, because each bottle tells its own story—with its dusty caps and sedimented bottoms, its past-expiration dates, and prices marked down to a dollar or less. Their stories are about the superfruit that never really was, about the outdated formulas that ignored consumer trends and basic concepts of functional drinks. Their stories tell a lot about consumers, who are both less intelligent and smarter than is often realized.

On these shelves is a university of education for a product developer in how to keep products away from their final oblivion…

Help with life’s real issues

Today’s peri-COVID world is tiring and stressful, and that’s before turning on the TV or scrolling through one’s social media feed. Fewer people than ever have the disposable income to take a vacation or buy their next house. So, $3 for a temporary indulgence has become the Calgon bubble bath of the 2020s. The current demand has never been greater for more energy and less stress, filling in nutritional gaps, or just something satisfying that seems healthy. Today more than ever, for better or worse, enjoyment often comes in a bottle or can.

Minimize sugar and “junk”

Sure, sugar tastes good. (Really good). And it secretly wants to kill us softly with its song. And consumers, now accustomed to the taste of noncaloric sweeteners, are increasingly willing to sacrifice a little bit of that authentic sugary flavor for what they perceive as a real benefit. (And did I mention, health is top of mind now?)

Then there’s “junk,” which like beauty, is in the eye of the beholder. It’s always interesting to see each brand’s unique take on what junk means to them. But looking at a population of products in a category, repeated definitions of junk emerge, which must mean something—at least in terms of anticipated demand. The junk ingredients have funny or chemical-sounding names, and don’t state the ingredient’s natural source or purpose. At the same time, the “not junk” ingredients are typically from plants, and are often called “organic,” whatever that means in reality. Whether one agrees with the meaning of junk ingredients, it’s fair to say that in general, natural, plant-based is better. (Although isn’t sugar from a plant too? But I digress.)

Meaningfully different, yet familiar

The drink market is crowded and challenging. Sure, a brand could launch another me-too flavored water with antioxidants, but turning a profit on knockoffs requires brute strength, patient investors and a lot of luck. Meeting high-demand and up-trending needs in a new and meaningful way is the holy grail, and hitting on this combination requires a mix of familiar yet different. And still, what’s different needs to be meaningful to the consumer, and provide a clear benefit that competitors have difficulty offering.

Natural ingredients with a simple, science-based story

Imagine for a moment a new superfruit called the bubbleberry—claimed to have magical antioxidant powers. Plenty of superfruits have come and gone whose long-term value didn’t live up to their hype. Some critical questions on “hero” ingredients like the bubbleberry should be answered before their promise is burst. Namely, why should consumers care about the bubbleberry? What are its benefits, and will it make the consumer feel good about their purchase? Does the science support its claims, much less its safety for all types of people? And especially, where on Earth is this magical berry grown and processed, how is it grown and processed, and by whom?

The past few decades have brought a number of safe, clinically proven ingredients to choose from, and suppliers who have dedicated their entire business to developing them. There’s no need to find the next bubbleberry when options already exist with validated science, benefits and safety.

Avoiding the shelf of product oblivion means learning from the textbook of product failures, and understanding the rapidly changing needs of the current consumer. Let’s not forget the lessons history had to teach us—especially at the end of a product’s lifespan.

Product Strategy Consultants for Dietary Supplements

by NaturPro in Uncategorized Comments: 4

Product strategy for health products like supplements requires extensive knowledge of consumer trends, marketing, consumer behavior, food science, regulatory requirements and technical and scientific affairs.

NaturPro Scientific combines expertise in a wide array of product types and disciplines, offering clients a way to maximize chances for consumer product success in the market.

Product Strategy – Cores of Discipline 

A product may be determined as safe and effective, and also legal and kosher — but still not be positioned for success.  For example, it may be undifferentiated in a crowded market, or not provide a meaningful benefit that is valued by the consumer. A great product may find itself swimming in infested waters filled with competitors.

Supplement capsules prototype pilot samples
NaturPro offers seed-to-shelf strategy and execution for supplement product development

 Our in-depth analysis and advisory process helps to guide our clients in the right direction.

Some main considerations for any supplement product design consultants includes the following:

  1. Target Health Category(s) and subcategories, including potential niche markets
  2. Market Opportunity Analysis
  3. Market Size & Market Leaders
  4. Key Competitor Analysis
  5. Pricing Sensitivity
  6. Consumer Preference Analysis, including consumner surveys and focus groups
  7. Key Product Benefit
  8. Regulatory Review
  9. Customer Demographics
  10. Differentiation, Positioning and Competitive Analysis
  11. Innovation Strategy
  12. SWOT Analaysis
  13. Marketing and Distribution Channel Analysis

Healthy Food and Supplement Beverage Formulators


Creating a successful healthy food or beverage is a lot more than selecting a list of ingredients that mix well together.

NaturPro has a broad base of knowledge in product development and production of dietary supplements, healthy foods and healthy beverages, spanning from raw material to finished functional food or beverage.

We guide our clients in the right direction, by helping to manage all or parts of the process for healthy food and beverage formulation and development — from seed to shelf — for dietary supplement and health food products.

NaturPro offers beverage formulation support for healthy drinks

Functional Food and Drink Development

Our client list includes folks of all shapes and sizes, from startup to large corporation.

No two clients or products are the same, but there are some common approaches found in our Product Development Toolbox:

Product Development Toolbox: Top 5 Product Development Tools:

Product development requires a ‘toolbox’ of analysis including the following

  1. Market Analysis, Competitive Analysis and Positioning
  2. Regulatory Status / Safety Assessment
  3. Claims Development and Substantiation
  4. Product Costing and Financials
  5. Ingredient Readiness, Supplier Qualification

Contact Us

Pilot and Benchtop Prototype Capsules & Powders for Dietary Supplements


Creating a successful pilot and bench top prototype capsule is a lot more than creating a list of ingredients that mix well together.

NaturPro has a broad base of knowledge in capsule development and prototype formulation as well as healthy foods and natural products, spanning from raw material to finished consumer product.

We guide our clients in the right direction, by helping to manage all or parts of the process for natural product formulation and development — from seed to shelf — for dietary supplement and health food products.

NaturPro offers supplement prototypes, R&D pilot production for capsules and powders

Product Prototypes and Samples

Our client list includes folks of all shapes and sizes, from startup to large corporation. Many of them need small runs of new or custom products for stability and human survey trials.

No two clients or projects are the same, but there are some common approaches found in our Development Toolbox:

Imagine the Possibilities…

Supplement Custom Packaging Copacker Manufacturing
We do supplement Custom Packaging, because your Copacker or Contract Manufacturer is probably not thinking about creative ways to package your product..

Product Development Toolbox: Top 10 Developer’s Tools:

Product development for dietary supplement capsules requires a ‘toolbox’ of analysis including the following

  • Market Analysis, Competitive Analysis and Positioning
Brain Supplement Nootropic Food Beverage Drink
Where is your concept in the mindshare of your target customer?
  • Regulatory Status / Safety Assessment — GRAS | ODI | NDI
Regulatory compliance quality supplements food
Regulatory compliance and quality assurance for supplements and food ingredients
Supplement Product Claims Science Clinicals
Supplement Product Claims Depends on Your Science and Clinicals — In Writing.
Supplement Product Financials Costs Margins
It’s critical to know your product and ingredient financials, including costs and margins.
Supplier Qualification Ingredients
Supplier qualification and ingredients vetting are key functions of all new product development.
Ingredient Specifications Specs Verification
Ingredient specifications and verification of specs are central parts of the process

Contact Us

Dietary Supplement Facts and Label Review


There’s a lot of detail required for dietary supplement labels. Between supplement facts, structure-function health claims, content claims, and required formatting, it’s easy to overlook some of the FDA requirements for labeling.

Supplement Label Review Nutrition Facts

Supplement Label Review for Supplement Facts, Nutrition Labeling and Claims

Dietary Supplement Facts and Label Review

As part of our Label Review services, NaturPro helps clients develop, review and suggest improvements to dietary supplement labels, to ensure compliance with FDA regulatory requirements

Our clients enjoy the following benefits:

  1. Reliability: 100% accuracy and FDA compliance
  2. Experience: 15+ years of experience reviewing supplement labels
  3. Science-driven: Our reviews are based on the most current, reliable information, techniques and evidence
  4. Perspective: We have experience on the business side of the industry, so we know what the law is, whether it’s followed, and what is likely to happen if you don’t.

Updated Pricing:

Label Review (Basic): $350-550  — review only label — for “red flags” and suggested improvements

Label Review (Complete): $550-850 – review of label for red flags and suggested improvements, and matching finished product specifications

Label and Marketing Review: $800-1500 per label – web page / sales sheet

 (Volume discounts may apply for similarly labeled products — Contact for Pricing


FDA Dietary Supplement Labeling Guidelines

See our Dietary Supplement Label Review Checklist.

The following outlines some of the most frequently asked questions (FAQ) for dietary supplement labels:

  1. How are dietary supplements defined?Dietary supplements are defined, in part, as products (other than tobacco) intended to supplement the diet that bear or contain one or more of the following dietary ingredients:
    1. A vitamin;
    2. A mineral;
    3. An herb or other botanical;
    4. An amino acid;
    5. A dietary substance for use by man to supplement the diet by increasing the total dietary intake; or
    6. A concentrate, metabolite, constituent, extract, or a combination of any ingredient mentioned above.Further, dietary supplements are products intended for ingestion, are not represented for use as a conventional food or as a sole item of a meal or the diet, and are labeled as dietary supplements.
  2.  What label statements are required on the containers and packages of dietary supplements?Five statements are required: 1) the statement of identity (name of the dietary supplement), 2) the net quantity of contents statement (amount of the dietary supplement), 3) the nutrition labeling, 4) the ingredient list, and 5) the name and place of business of the manufacturer, packer, or distributor.
  3.  Where do I place the required label statements?You must place all required label statements either on the front label panel (the principal display panel) or on the information panel (usually the label panel immediately to the right of the principal display panel, as seen by the consumer when facing the product), unless otherwise specified by regulation (i.e., exemptions).
  4.  What label statements must I place on the principal display panel?You must place the statement of identity and the net quantity of contents statement on the principal display panel. Where packages bear alternate principal display panels, you must place this information on each alternate principal display panel.
  5.  How do I locate the principal display panel?The principal display panel of the label is the portion of the package that is most likely to be seen by the consumer at the time of display for retail purchase. Many containers are designed with two or more different surfaces that are suitable for use as the principal display panel. These are alternate principal display panels.
  6.  What label statements must I place on the information panel?You must place the “Supplement Facts” panel, the ingredient list, and the name and place of business of the manufacturer, packer, or distributor on the information panel if such information does not appear on the principal display panel, except that if space is insufficient, you may use the special provisions on the “Supplement Facts” panel in 21 CFR 101.36(i)(2)(iii) and (i)(5). See questions 46 and 56 in Chapter IV for more details.
  7.  Where is the information panel?The information panel is located immediately to the right of the principal display panel as the product is displayed to the consumer. If this panel is not usable, due to package design and construction (e.g. folded flaps), the panel immediately contiguous and to the right of this part may be used for the information panel. The information panel may be any adjacent panel when the top of a container is the principal display panel.
  8.  What name and address must I list on the label of my product?You must list the street address if it is not listed in a current city directory or telephone book, the city or town, the state, and zip code. You may list the address of the principal place of business in lieu of the actual address.
  9.  May I place intervening material on the information panel?No. You may not place intervening material, which is defined as label information that is not required (e.g., UPC bar code), between label information that is required on the information panel.
  10.  What type size, prominence and conspicuousness am I required to use on the principal display panel and the information panel?You are required to use a print or type size that is prominent, conspicuous and easy to read. The letters must be at least one-sixteenth (1/16) inch in height based on the lower case letter “o,” and not be more than three times as high as they are wide, unless you petition for an exemption in accordance with 21 CFR 101.2(f). The lettering must contrast sufficiently (it does not need to be black and white) with the background so as to be easy to read. See Chapter IV for the type size requirements for the nutrition label.
  11.  Do I need to specify the country of origin if my product, or the ingredients in my product, is not from the United States?Yes. Unless excepted by law, the Tariff Act requires that every article of foreign origin (or its container) imported into the United States conspicuously indicate the English name of the country of origin of the article.
  12. What is the nutrition label for a dietary supplement called?The nutrition label for a dietary supplement is called a “Supplement Facts” panel.
    1. You must list dietary ingredients without RDIs or DRVs in the “Supplement Facts” panel for dietary supplements. You are not permitted to list these ingredients in the “Nutrition Facts” panel for foods.
    2. You may list the source of a dietary ingredient in the “Supplement Facts” panel for dietary supplements. You cannot list the source of a dietary ingredient in the “Nutrition Facts” panel for foods.
    3. You are not required to list the source of a dietary ingredient in the ingredient statement for dietary supplements if it is listed in the “Supplement Facts” panel.
    4. You must include the part of the plant from which a dietary ingredient is derived in the “Supplement Facts” panel for dietary supplements. You are not permitted to list the part of a plant in the “Nutrition Facts” panel for foods.
    5. You are not permitted to list “zero” amounts of nutrients in the “Supplement Facts” panel for dietary supplements. You are required to list “zero” amounts of nutrients in the “Nutrition Facts” panel for food.How does “Supplement Facts” differ from “nutrition facts?”The major differences between “Supplement Facts” panel and “Nutrition Facts” panel are as follows:
  13. What information must I list in the “Supplement Facts” panel?You must list the names and quantities of dietary ingredients present in your product, the “Serving Size” and the “Servings Per Container.” However, the listing of “Servings Per Container” is not required when it is the same information as in the net quantity of contents statement. For example, when the net quantity of contents statement is 100 tablets and the “Serving Size” is one tablet, the “Serving Per Container” also would be 100 tablets and would not need to be listed.
  14. How must I display the “Supplement Facts” panel?The “Supplement Facts” nutrition information (referred to as a panel) must be enclosed in a box by using hairlines. The title, “Supplement Facts,” must be larger than all other print in the panel and, unless impractical, must be set full width of the panel. The title and all headings must be bolded to distinguish them from other information.
  15. How must I present the information in the “Supplement Facts” panel?You must present all information using the following:
    1. A single easy-to-read type style;
    2. All black or one color type, printed on a white or neutral contrasting background, whenever practical;
    3. Upper- and lowercase letters, except that you may use all uppercase lettering on small packages (i.e., packages having a total surface area available to bear labeling of less than 12 square inches);
    4. At least one point leading (i.e., space between lines of text); and
    5. Letters that do not touch.

  16. What are the type size requirements for the “Supplement Facts” panel?Except as provided for small and intermediate-sized packages, you must set information other than the title, headings, and footnotes in uniform type size no smaller than 8 point. You also must use a type size larger than all other print size in the nutrition label for the title “Supplement Facts.” You may set the column headings and footnotes in type no smaller than 6 point type. See the section on “Special Labeling Provisions” for the exceptions for small and intermediate-sized packages.
    For more information, visit FDA Dietary Supplement Labeling Guide

Dietary Supplement Recall


January 17, 2020 — Dietary Supplement Recall announced for 1,200 products from 850 supplement distributors made between January 2013 and November 2019.

FDA Supplement Recall
FDA Supplement Recall on 1200 product from 850 companies made from 2013-2019

ABH NATURE’S PRODUCTS, INC, ABH PHARMA, INC., and STOCKNUTRA.COM, INC. (the “COMPANIES”) is conducting a nationwide recall of ALL lots of its dietary supplement products pursuant to a Consent Decree entered by the U.S. District Court for the Eastern District of New York. This recall applies to all dietary supplement products manufactured and sold between January 2013 – November 2019 and all lots of products are included in this recall.

These products are being recalled after an FDA inspection found significant violations of current good manufacturing practice regulations. Manufacturing practices that are not in adequate control represent the possibility of risk being introduced into the manufacturing process resulting in finished supplement products with decreased identity, purity, strength and composition.

To date, there have been no reported illnesses or injuries as a result of this situation.

The COMPANIES contract manufactured dietary supplements for other firms and did not sell products directly to consumers. Link to Press Release


Contract Manufacturing Advocacy and Recall Prevention

It’s important to recognize the differences between GMP certification and GMP verification.

If you own a supplement brand, and are not 100% sure whether your supplement contract manufacturer is meeting FDA requirements, contact us.


Contract Supplement Manufacturer Advocates


Behind every successful product is a great contract supplement manufacturer.

We’ve audited and worked together with a lot of contract manufacturers.

That means we know how to get the best value, at the best quality, from supplement contract manufacturer partners.

NaturPro Verified Supply™

by NaturPro in Uncategorized Comments: 1

As consultants for a diversity of supplement and food firms, NaturPro Scientific has qualified numerous ingredients, suppliers and products.

So, we decided to share some of the products and ingredients that we have verified, within a curated supply catalog: NaturPro Verified Supply™

What’s different about NaturPro Verified Supply compared to other suppliers and manufacturers?

  1. Suppliers cannot pay to be listed. Unlike most suppliers, NaturPro does not accept fees or commissions to represent or promote any specific ingredients or products. Our core business is in vetting the best ingredients and products — not selling them.
  2. We are not tied or committed to any one ingredient or supplier, so we can keep our standards high.
  3. Our vetting process goes beyond FDA regulatory requirements. NaturPro standards include our intimate understanding of supplier practices, supply chain quality, sustainability, GMP’s, best practices, traceability to source, a track record of integrity, and a demonstrated commitment to quality and research.

Connect to NaturPro Verified Supply™ Portal

Contact us with questions or comments!

Ethical Sourcing Assessments for Ingredients, Supplements and Foods

by NaturPro in Uncategorized Comments: 4

NaturPro has served an essential role in helping our clients source and evaluate ethically sourced ingredients. 

Our Ethical Sourcing Assessments include elements from many recognized programs such as Fairtrade(R), and uses one of the most comprehensive set of standards guiding the evaluation of the social and environmental impact of natural products and foods.

Ethical Sourcing Assessments are Key to Understanding Social, Environmental and Product Sustainability

Ethical Sourcing of Ingredients for Supplements and Foods
Ethical Sourcing of Ingredients for Supplements and Food is used to benchmark sustainability and identify ways to improve supply chains.

The following outline covers subject matter covered in our evaluation protocol, which is derived from multiple sources, including the International Labour Organization Labour Principles of the United Nations Global Compact, the UN Forum on Sustainability Standards, Fairtrade,, WHO GAP, Global G.A.P., and NOP Organic.

General Guidelines for Ethical Sourcing: The Human Element

Product:

  1. Contact information
  2. Product name
  3. Specifications, nomenclature
  4. Sourcing origin
  5. Land use and inputs
  6. Harvest practices
  7. Plant population care
  8. Raw material processing and labeling

Relationships

  1. Type and controls
  2. Prices and wages
  3. Non-discrimination
  4. Reciprocity
  5. Communications

Employment

  1. Labor practices
  2. Fair wages and prices
  3. Child labor
  4. Harrassment
  5. Working conditions
  6. Worker safety

Environment

  1. Legal requirements
  2. Policies and communications
  3. Management responsibilities
  4. Waste management
  5. Emissions
  6. Energy usage

Management and Supply Chain

  1. Written policies
  2. Training
  3. Supplier management
  4. Dealing with non-compliances
  5. Audit program
  6. Geographic risk
  7. Community improvements

NaturPro fits our review protocol and minimum standards according to your practices currently in place, and we also evaluate according to the ‘stretch goal’ standards our clients are working to achieve, and set a clear path towards improved social and environmental impact.

Global Herb Producer Cooperative
Reviewing your ‘people practices’ helps our clients to better understand and support their supply chain.

Here are a couple examples of case studies we have performed for clients:

1. “Seed-to-Shelf Independent Audit” — A comprehensive, umbrella independent review of all quality and ethical procedures, relating to both farm-level and manufacturing practices.

We review all documentation, audit reports and other information, provide a list of opportunities to improve quality, identify gaps that minimize business, regulatory and product quality risk, help our clients meet the minimum level of regulatory compliance, and identify ‘best practices’ that are either already in place, or can be implemented. 


2. “Human Impact Audit” – A third-party independent review of the “human element” of an agricultural or wild-collected product, focusing in particular on staff training, farming practices and GAP, worker health and safety, and cultural preservation.   This includes a review of personnel SOP, safety, fair trade, farm practices, environmental impact estimates, ethical sourcing & organic practices.

The above 2 programs could be done separately or combined, and are typically performed in 2 phases: 

Phase 1: Document Audit
Phase 2: In-person/field Audits

3. Program marketing and communications – A comprehensive review paper that describes in detail all the elements of the program, references to the standards applied, and images or video footage. This comprehensive review can then be broken down into separate stories, that can become webpages, Youtube videos and social media posts that educate your audience.

Contact us for more information on NaturPro Scientific’s ingredient traceability and ethical sourcing programs.