Avoiding Big, Fat Supplement Problems
Beginning where I left off with my last post, here is my “Top 10 List for Supplement Companies Getting Into Weight Loss”:
1. Make sure your proprietary active ingredient or formula has a sufficient body of characterization, pharmacokinetic, safety, efficacy and stability data to withstand regulatory scrutiny from all countries whose markets you are considering. Get regulatory counsel with experience in national and international dossiers and submissions.
2. Aim for a safe dosage level that will yield a narrow weight-loss average of 1-2 pounds per week.
3. Always choose the highest quality ingredients and vendors and make sure that your facility, and your vendors’, meet or exceed the highest level of cGMP compliance.
4. Ensure that all of your packaging, labeling and marketing materials are fully FDA- and FTC-compliant, and compliant with other jurisdictions, as the case may be.
5. Always make any claims part of (or linked to) an overall lifestyle approach to improved body composition, one that includes a healthy diet and physical activity regimen, and ensure that an appropriate disclaimer to this effect is prominently displayed on all packaging and marketing materials.
6. Make sure that all claims (including structure-function) are approved by in-house counsel, and if need be, vetted by outside legal experts.
7. If possible, steer clear of the use of any testimonials. If a testimonial must be used, make sure that it is from a real customer and reflects typical results.
8. Never use any inflated or high-flying language or claims, especially anything using these words or similar: miracle, cures, breakthrough, secret ingredient, ancient remedy, no-risk money-back guarantee, rapid weight loss, etc.
9. Take advantage of self-regulatory resources, such as that provided by CRN and the Better Business Bureau’s National Advertising Division, or webinars offered by the Natural Products Association.
10. Take advantage of industry resources, such as the Natural Products INSIDER “Weight Management Immersion Center” currently sponsored by Kemin Foods.
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