Testing Foods, Supplements and Ingredients

The mass confusion around quality testing has brought more awareness to the issue, but the industry is still lacking clear guidance on how to deal with some of the practical issues. That’s why NaturPro offers independent laboratory support for food & supplement testing for natural products.

Have natural product analysis questions? Contact Us..

Why Testing is Important: Supplement and natural product testing with a compliant laboratory is required by FDA for foods, dietary supplements and ingredients to ensure they meet standards for safety, quality and effectiveness. For example, identity, potency and purity are quality control parameters needed to legally sell a natural product as an ingredient, food or dietary supplement.

NaturPro Scientific is driven to achieve the right answers for our clients.  Some have even called us the UnLab. Why?

Being independent means that we do not own or have interest in any laboratory, which means we are free to pick from the top scientific experts for each type of test or analysis. As a result, we are truly able to work on behalf of our clients, to ensure that correct methods are used and results are obtained.

Natural Product and Supplement Testing Consultants

We know which labs are experienced with ginseng, but not with ginkgo — and this can mean a world of difference in test results.

8 reasons to use a supplement testing consultant for dietary supplements:

1. To ensure analytical methods used are valid and fit for purpose
2. To make sure laboratories don’t take shortcuts with your sample
3. To determine if results are precise and accurate
4. To replicate the results of another lab
5. To resolve out-of-specification test results
6. To resolve disputes in data reports
7. To determine if “dry-labbing” may be occurring
8. To have an independent expert to review methods and results

3 main benefits of food and dietary supplements testing consultants:

1. Better analysis and testing validity  for reliable, replicable and defensible results.
2. Fast turnaround and lower testing costs.
3. Reduced retesting, rejections, production delays and product recalls.

Bottom Line – NaturPro knows the right methods and labs to use, and the right questions to ask. We know the shortcuts that testing labs can take, and how to prevent that from happening to you, to ensure testing gives the most scientific, accurate and defensible results possible.

Contact Us with your Testing Questions

NaturPro Scientific stands out as consultants who work for our clients. We help our clients creating a successful dietary supplement by helping with Audits and GMPs.

Audits are an integral part of the licensing and ongoing regulatory compliance process for dietary supplements. Audits can be rigorous, and are seen as a true ‘stress test’ on your quality system.

The 4 main benefits of our audits (among many) include:

• Understanding where you are may not meet regulatory requirements
• Provide reviews and recommendations from a fresh perspective
• Train your staff on dealing with regulatory audits
• Reduce the risk of a food safety issue or costly product recall.

Types of Supplement Audits

Pre-License Audits
Prior to issuing a license (e.g.,  Cultivation, Processor, Retail), regulators may require demonstration  compliance with the relevant cannabis regulation, and to ensure implementation of critical regulatory requirements such as physical security requirements, recordkeeping and good production practices. Licensed cannabis firms are required to demonstrate regulatory compliance at these audits in order to achieve (and maintain) their license.

Introductory Audits

An introductory audit may be scheduled after the pre-licensing audit, when the licensee is ready to start production. NaturPro Scientific is often hired to participate in and support our clients before, during and after regulatory audits. This audit is conducted to verify compliance against regulations in addition to inventory control/activities.

GMP Audit 
This type of audit assesses compliance against established Good Manufacturing Process (GMP) guidelines. Our experts have extensive experience with GMP audits to assist cultivators and processors  identify gaps against the regulations/standards, and putting appropriate corrective and preventative actions in place.

Quality Assurance
NaturPro has FDA-trained food safety experts (PCQI) and chemists on staff, and we are often called to perform duties of a Quality Manager for our clients. We handle and interpret lab testing, support supply chain and supplier qualification based on best practices for cannabis and botanical drugs.

Contact Us

• Email: [email protected]
• Website: www.npscientific.com
• Twitter: @NaturalBlake
• Instagram: @NaturPro

NaturPro Scientific is a recognized leader in GMP(Good Manufacturing Practices) for dietary supplements and foods.

What are Good Manufacturing Practices?  Good Manufacturing Practices (GMP) ensures products are consistently produced and controlled to the quality standards and conform to all applicable regulatory requirements.  Good Manufacturing Practices are fundamental to any manufacturing industry and are often required to be implemented in plants and factories by national governments.  Our team of experts can assist you with the development and evaluation of GMP programs  for dietary supplement products.

We help you to train qualified staff, get in-depth and correct understanding of standards, and establish comprehensive management systems.

Here are some of the services we offer for cannabis compliance:

• Audits
  • Preliminary Gap Analysis
  • Facility GMP pre-audits
  • Internal Audits
  • Third-Party Audits
  • CAPA Audits
• Quality Management
• Materials Testing
• Process Approvals
• Documentation and SOP
  1. Quality Manual
  2. Recordkeeping
  3. Document Control
  4. Traceability & Recall
     1. Formula Records
     2. Batch Records
     3. Certificates of Analysis
  5. Risk Analysis
     1. Hazard Analysis
     2. Purchasing Criteria & Specifications
  6. Supplier Qualification
  7. Preventive Controls
  8. Product Approval & Rejection, Material Inspection
  9. Complaints & CAPA (Corrective Actions)
  10. Quality Issue Investigation and Resolution
• Training and Hiring
• Investor Due Diligence

NaturPro Scientific are Consultants for GMPs

NaturPro works closely with our clients to provide the most cost effective way to achieve GMP certification and an edge in the market.

The 4 main benefits of our audits (among many) include:

1. Understanding where you are may not meet regulatory requirements
2. Provide reviews and recommendations from a fresh perspective
3. Train your staff on dealing with regulatory audits
4. Reduce the risk of a food safety issue or costly product recall.

Pre-License Audits
Prior to issuing a license (e.g.,  Cultivation, Processor, Retail), regulators may require demonstration  compliance with the relevant dietary regulation, and to ensure implementation of critical regulatory requirements such as physical security requirements, record keeping and good production practices.

Introductory Audits

An introductory audit may be scheduled after the pre-licensing audit, when the licensee is ready to start production. NaturPro Scientific is often hired to participate in and support our clients before, during and after regulatory audits. This audit is conducted to verify compliance against regulations in addition to inventory control/activities.

GMP Audit 
This type of audit assesses compliance against established Good Manufacturing Process (GMP) guidelines. Our experts have extensive experience with GMP audits to assist cultivators and processors  identify gaps against the regulations/standards, and putting appropriate corrective and preventative actions in place.

Quality Assurance
NaturPro has FDA-trained food safety experts (PCQI) and chemists on staff, and we are often called to perform duties of a Quality Manager for our clients. We handle and interpret lab testing, support supply chain and supplier qualification based on best practices for dietary supplements.

As Supplement Label Consultants we often are asked what we think of a product claim. The thought process to develop an answer is generally similar, regardless of the type of product, and whether its finished product, or an ingredient or raw material.

The Food & Drug Administration (FDA) has specific rules for labeling and claims related to dietary supplements on packaging, marketing, websites, inserts and other promotional materials. If a label states a false or misleading claim, FDA, other regulatory agencies or class-action attorneys may file warning letters or lawsuits.

Dietary Supplement Label Review Checklist

As Consultants at NaturPro we have a checklist we follow to ensure we help make the label for you product.

⊗ PACKAGING REQUIREMENTS

Five general requirements for labels include: 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 (Supplement Facts Panel), 4) the ingredient list, and 5) the name and place of business of the manufacturer, packer, or distributor.

⊗ 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 theconsumer when facing the product), unless otherwise specified by regulation(i.e., exemptions).

⊗ SUPPLEMENT FACTS PANEL

Total calories, calories from fat, total fat, saturated fat, cholesterol, sodium, totalcarbohydrate, dietary fiber, sugars, protein, vitamin A, vitamin C, calcium, andiron must be listed when they are present in measurable amounts. Calories from saturated fat and the amount of polyunsaturated fat, monounsaturated fat, soluble fiber, insoluble fiber, sugar alcohol, and other carbohydrate may be declared, but they must be declared when a claim is made about them.

⊗ INGREDIENT LIST

When present, you must place the ingredient list on dietary supplementsimmediately below the nutrition label, or if there is insufficient space belowthe nutrition label, immediately contiguous and to the right of the
nutrition label.

⊗ WARNING STATEMENT

FDA requires warning statements related to safety and special precautions that, if not followed, could make the product unsafe.

⊗ UNITS OF MEASUREMENT

Proper units of measurement must be used, for example milligrams (mg), micrograms (mcg) or other appropriate units

⊗ PERCENTAGE DAILY VALUE (DV)

The % DV must be declared for all dietary ingredients for which FDA has established Daily Values, except that 1) the percent for protein may be omitted, and 2) on the labels of dietary supplements to be used by infants, children less than 4 years of age, or pregnant or lactating women, you must not list any percent for total fat, saturated fat, cholesterol, total carbohydrate,dietary fiber, vitamin K, selenium, manganese, chromium, molybdenum,chloride, sodium, or potassium.

⊗ DOMESTIC ADDRESS OR PHONE NUMBER

The label of a dietary supplement being marketed in the United States must include a domestic address or domestic phone number through which the responsible person may receive a report of a serious adverse event with such dietary supplement. If the label does not include the required domestic address or phone number, the dietary supplement is misbranded.

⊗ UPC BAR CODE

The UPC bar code may be obtained from the Uniform Code Council (www.uc-council.org)

⊗ NATURAL AND ARTIFICIAL FLAVORS

You must declare these ingredients in ingredient lists by using either specific common or usual names or by using the declarations  “natural flavor” or “artificial flavor,” or any combination thereof.

⊗ CHEMICAL PRESERVATIVES

You must list the common or usual name of the preservative, which may be followed by a description that explains its function e.g., “preservative,” “to retard spoilage,”“a mold inhibitor,” “to help protect flavor,” or “to promote color retention.”

⊗ OTHER DIETARY INGREDIENTS

You must list “other dietary ingredients” by common or usual name in acolumn or linear display. FDA has not specified an order that you must follow. You must list the quantitative amount by weight per serving immediately following the name of the dietary ingredient or in a separate column. You must place a symbol in the column for “% Daily Value” that refers to the footnote “Daily Value Not Established,” except that the symbol must follow the weight when you do not use the column format.

⊗ LIQUID EXTRACTS

You must list liquid extracts using the volume or weight of the total extract and the condition of the starting material prior to extraction when it was fresh. You may include information on the concentration of the dietary ingredient and the solvent used. The solvent must be identified in either the nutrition label or ingredient list.

⊗ DRIED EXTRACTS

For dietary ingredients that are extracts from which the solvent has been removed, you must list the weights of the dried extracts.

⊗ CONSTITUENTS

You may list constituents of a dietary ingredient indented under the dietary ingredient and followed by their quantitative amounts by weight per serving. You may declare the constituents in a column or in a linear display.

⊗ PROPRIETARY BLENDS

You must identify proprietary blends by use of the term “Proprietary Blend” or an appropriately descriptive term or fanciful name. On the same line, you must list the total weight of all “other dietary ingredients” contained in the blend. Indented underneath the name of the blend, you must list the “other dietary ingredients” in the blend, either in a column or linear fashion, in descending order of predominance by weight. These ingredients should be followed by a symbol referring to the footnote “Daily Value Not Established.”Dietary ingredients having RDIs or DRVs must be listed separately and the individual weights declared.

⊗ PRODUCT CLAIMS

Claims come in four basic varieties:

• structure/function claims
• disease claims
• health claims and qualified health claims
• content claims

Basically, dietary supplements cannot make “disease” claims (for example: “treats cancer”). Dietary supplements that make disease claims are considered by FDA as drugs.

Dietary supplements can make “structure/function” claims (for example, “calcium builds strong bones”). A structure/function claim describes the product’s role in maintaining the “structure or function of the body,” or “general well-being.”

The Federal Trade Commission (“FTC”) has overlapping jurisdiction with the federal Food and Drug Administration (“FDA”), and focuses more on whether advertising is truthful, or false and misleading. Thus, it is important to respect nuanced labeling rules, including those regarding the statement of the identity.⊗HIGH POTENCY CLAIMS

The regulation states that the term “high potency” may be used in a claim on the label or in labeling to describe individual vitamins or minerals thatare present at 100 percent or more of the Reference Daily Intakes (RDI) per reference amount customarily consumed (21 CFR 101.54(f)(1)(i)). This means a supplement may be labeled as “high potency” for each nutrient(s) that is present at 100% of the RDI per serving.

⊗ ANTIOXIDANT NUTRIENT CONTENT CLAIMS

A claim that describes the level of antioxidant nutrients present in a food is a nutrient content claim and may be used on the label or in the labeling of a food when the conditions of use in the regulation are met (21 CFR 101.54(g)).

The antioxidant nutrient must meet the requirements for nutrient content claims in 21 CFR 101.54.

⊗SUGAR-FREE CLAIMS

A dietary supplement may include claims in labeling such as “sugar free,” “no sugar,” or other claims provided it meets all of the eligibility criteria set forth in the regulation.

Among other requirements, a food must be labeled as “low calorie” or “reduced calorie” or bear a relative claim of special dietary usefulness. However, a dietary supplement that is prohibited from bearing a “low calorie”or “reduced calorie” claim can still use a sugar-free claim provided it meets the “low calorie” requirement in 21 CFR 101.60.

⊗HIGH OR GOOD SOURCE CLAIMS

You may make a “high” claim when your dietary supplement contains atleast 20% of the Daily Value (DV) (i.e. the Reference Daily Intake (RDI) or Daily Reference Value (DRV)) of the nutrient that is the subject of the claim perreference amount customarily consumed. You may make a “good source”claim when your dietary supplement contains 10 to 19% of DV.

⊗ LOW OR FREE-FROM CLAIMS

If a similar dietary supplement is normally expected to contain a nutrient and your dietary supplement is specially processed, altered, formulated, or reformulated as to lower the amount of the nutrient in the food, remove the nutrient in the food, or not include the nutrient, then you are permitted to make a “low” or “free” claim as applicable.

⊗ LOW CALORIE CLAIMS

A “low calorie” claim may not be made on dietary supplements, except when an equivalent amount of a dietary supplement that the labeled dietary supplement resembles and for which it substitutes (e.g., another protein supplement), normally exceeds the definition for “low calorie.”

⊗ QUALIFIED HEALTH CLAIMS

FDA will permit the use of a qualified health claim provided that 1) FDA hasissued a letter stating the conditions under which we will consider exercisingenforcement discretion for the specific health claim, 2) the qualified claim is accompanied by an agency-approved disclaimer, and 3) the claim meets all the general requirements for health claims in 21 CFR 101.14, except forthe requirement that the evidence for the claim meet the validity standard for authorizing a claim, and the requirement that the claim be made in accordance with an authorizing regulation.

This guidance was prepared by the Office of Nutritional Products, Labeling and Dietary Supplements (ONPLDS) in the Center for Food Safety and Applied Nutrition (CFSAN) at the U.S. Food and Drug Administration.

Further reading:

Article: Food and Supplement Claims with Confidence

Food and Supplement Testing for Natural Products

Dietary Supplement Facts and Label Review FAQ

Dietary Supplement and Food Label Review