Country-Of-Origin Labeling Would Add Costs But No Consumer Benefit – CRN

Requiring country-of-origin labeling for dietary supplements would be redundant with good manufacturing practices and could raise prices without benefiting consumers, according to the Council for Responsible Nutrition.

With supplement GMPs already requiring stringent ingredient testing and recordkeeping, "all that information is readily available if the FDA chooses to investigate" a product, Mike Greene, CRN senior director of government relations, said Sept. 24.

In a Sept. 19 position statement, the trade group explains that the source of an ingredient is irrelevant to a consumer compared to "knowing the manufacturer has imposed high standards at every step of production," which GMPs aim to provide.

Greene maintained that COO labeling might prompt consumers to buy products based on the country of origin rather than on the manufacturer's reputation.

"We don't want to fuel flames and fires about xenophobia," he said. Instead, labels should help "assure consumers that their dietary supplements are made to high-quality standards, regardless of whether they come from across town or across the world."

The GMPs require manufacturers to qualify their suppliers and conduct identify testing of ingredients. Those processes create records of where ingredients originate, which can be traced by FDA.

Concerns in Congress, at FDA and in the public about foreign ingredients have mounted in response to a series of incidents of contamination related to products from China that have been reported over the last two years. The most recent reports relate to milk-based products from China contaminated with melamine.

A draft bill addressing FDA enforcement reform proposed by House Energy and Commerce Committee Chairman John Dingell, D-Mich., includes COO labeling for foods, drugs and devices (¹ (Also see "Dingell Import Safety Bill Includes User Fees To Fund Foreign Inspections" - Pink Sheet, 24 Sep, 2007.), p. 4).

In the Senate, Illinois Democrat Dick Durbin has put forth multiple food safety bills in the current Congress, one with a COO labeling provision and one without. Neither bill has yet moved out of committee (² (Also see "Senate Food Safety Bill Continues Congressional Quest To Expand FDA Powers" - Pink Sheet, 11 Aug, 2008.), p. 17).

According to Greene, the Bioterrorism Act of 2002 already sets strict guidelines for traceability of food and dietary supplement ingredients and requires firms to keep detailed records of manufacturing processes (³ (Also see "Bioterror Recordkeeping Final Rule Requires Compliance By 2006" - Pink Sheet, 13 Dec, 2004.), p. 17).

The costs of creating and updating such labels "would probably be shared with the consumer at some point," Greene said, adding that a COO list "could create an accordion label that would be ineffective" for understanding complex products with many ingredients, such as multivitamins.

Even maintaining an up-to-date COO inventory on a company's Web site would be challenging, given that ingredient sources change regularly and individual product batches may include materials from diverse suppliers, CRN says.

Both the Grocery Manufacturers Association and the National Association of Chain Drug Stores oppose a COO labeling requirement, pointing to the burden it would impose on manufacturers or retailers (⁴ (Also see "GMA Opposes Food Safety User Fees, Country-Of-Origin Labels" - Pink Sheet, 31 Mar, 2008.), p. 4 and ⁵ (Also see "“Superfluous” Country-Of-Origin Labeling Would Confuse Consumers – NACDS" - Pink Sheet, 5 May, 2008.), p. 4).

A food and drug import safety law is inevitable, Greene said, but it remains to be seen whether COO labeling will play a role in it.

He added that "we're all much better educated" about food safety due to health scares linked to peanut butter and lettuce during the past two years, but the supplement industry's focus on safety and quality predates the current era of food safety alarm.

At a meeting of the Dietary Supplement Caucus in Washington Sept. 23, Natural Products Association Executive Director and CEO David Seckman told congressional staffers that the trade group has been active in working with the Chinese government on testing raw supplement ingredients.

Still, even with GMPs in place, "we are very concerned about the quality of the products" in the supplement industry, especially as 95 percent of vitamin C now comes from China, Seckman said.

Some in the food industry say consumer concern about imported ingredients, especially from China, should not be underestimated, and that COO labeling is a strong likelihood down the road (⁶ (Also see "Safety Woes Make Country Of Origin Labeling “Foregone Conclusion” – Execs" - Pink Sheet, 15 Oct, 2007.), p. 9).

- Dan Schiff ([email protected])