After reading a research review on the adulteration of dietary supplements, I was inspired to write a confession. I work for a supplement company that gets complaints for being “too diligent” with our auditing and micro testing requirements, but I’ve seen enough to make me think twice about buying supplements online. If this confession makes you angry, remember this is a fake confession. The bad news is some supplement suppliers are ACTUALLY this negligent. The good news is you can spot the shady ones by asking the right questions…let me demonstrate.

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My Confession

If you were walking down the street and found a dollar, wouldn’t you take it? No wallet, just money, sitting on the ground. Isn’t the American Dream about seizing opportunity? About lifting one’s self up? Successful entrepreneurs know the value of taking risks. This is why I sell contaminated supplements. The demand, the perception, the precedent – it’s the shady supplement trifecta.

The Demand

In the US alone, consumers spend over $20 billion a year on dietary supplements[i]. Of course the word “supplement” is so vague it’s unhelpful, like calling sandals, stilettos and cowboy boots all “shoes”. Technically, a supplement is anything (powder, liquid, pills etc.) that adds to (hence the word “supplement”) the nutrient intake of the diet. Vitamins are the best example – that’s how supplements started: “Take this B-vitamin supplement because you’re not getting enough from your food.” We have defined intakes for vitamins, but how can you argue with someone who says you’re not getting enough ginkgo in your diet? YOU CAN’T. I win.

There is no “enough” with plants, that’s why I get to decide what “enough” means, and how much I want you to pay me for it. I can even dictate how much I’ll claim to give you, and how much I’ll actually give you. And no, those are not the same. I don’t really have to give you the amount of the plant extract I say because no one asks about my ingredient testing program before sending me money. With plant-based supplements, no one really knows how much you really need, and you can’t really prove if it’s working or not.

Take Ginkgo, for example. Ginkgo adulteration is widespread [ii] but my customers don’t know that. Ginkgo is incredibly popular (thank you, energy drink boom), despite how studies on ginkgo’s benefits are inconclusive[iii]. No one has proven for sure that ginkgo lives up to its reputation, but most consumers just need anecdotal evidence. The unpredictable power of anecdotal evidence is something some energy drink companies have learned the hard way. But my supplements work for the fake people on my website, which means it’ll work for you, too. If the supplement I sell you doesn’t work, maybe you just haven’t been taking it long enough. Still not convinced? That’s fine. I’ve got another product that’s twice as strong.

The burden is on me to have evidence my product works, but luckily no one ever asks me for that information. As consumer mistrust for Big Food increases, so do sales of plant-based supplements. It’s terribly ironic that people trust me and my fancy website more than a company that’s been around over fifty years, but I don’t dictate consumer perception (I just take advantage of it).

The Perception

Let’s face it, everybody knows that “natural” means “healthy”.  If something comes straight out of the ground, you should eat it right? It’s Mother Nature – how could anything so fresh and natural be bad for you? When has Mother Nature ever hurt anyone? The word “natural” has no real meaning or true legal definition[iv], but that doesn’t stop all the lawsuits about its proper use on a label. Consumer perception trumps all.

This is why I’m good at my job. Consumers nowadays are more worried about artificial ingredients than food-borne illness[v]. According to the World Health Organization, food-borne illness kills ~420,000 people a year, and one-third of those deaths are kids under 5 years old[vi]. Between 2009 and 2012, Salmonella, Listeria monocytogenes, and undeclared allergens made up about 90% of the recalls in the Reportable Food Registry[vii]. But no one ever asks me about my Allergen Control program. No one ever asks me if I test my product for any pathogens like E coli, salmonella, or Listeria.

Even if you did ask me about those things, even if you catch me in my lies and my negligence, I can still win. All I have to do is shut down my website and open a new one tomorrow. It takes less than a day to change my labels to a new name and get them printed at Office Depot. I’ll be gone before the FDA even knows I existed. This is what the Natural Products Association calls “fly-by-night” advertising[viii]. The FTC won’t come after me because I’m too small.

I’m not Big Food, but don’t ask me about my background. Please keep thinking like Chobani: chefs are automatically good people and chemists and food scientists are automatically bad people[ix]. Kindly believe that all ingredients you can pronounce are automatically better for you (unless it’s a hard to pronounce tropical plant extract, then it’s okay), all processing is bad (unless that process includes slicing, dicing, extraction, purification, blending, mashing…), and all raw food is better (unless it’s meat).

Remember that multi-state Salmonella outbreak linked to RAW Meal Organic products[x]? Didn’t think so. If that story got half the attention as the story about “Just Mayo” misusing the word “mayo”[xi], the raw food movement could’ve taken a serious reputation hit.

Don’t get me wrong, I do worry about the FDA. Many people think supplements have no regulations, and yet even that misconception doesn’t seem to faze anybody who wants to buy a supplement. Supplement regulations say I don’t have to get the FDA’s approval before I start selling these supplements, but I’m obligated to have proof my products are safe and effective. But I don’t have to give this proof to anyone unless they ask for it, and no one ever asks! It’s like driving without a driver’s license: people do it all the time, and it’s fine as long as you avoid any situation where someone’s going to ask for it. That said, please don’t ask me for this evidence.

The Precedent

You don’t have to reinvent the wheel to make a quick buck here. Trust the precedent. If you’re going to sell a weight-loss product, you should cut it with something. Pharmaceutical adulterants like appetite suppressors, stimulants, diuretics, and laxatives are very common weight-loss supplement adulterants because they will provide quicker effects than any real plant based supplement. If your customers don’t see or feel a difference, they won’t keep buying your stuff. It’s better to risk getting caught than risk losing potential word-of-mouth recommendations. And even if some consumers catch wind your product is adulterated, the extreme customers will want to buy it even more![xii] Show me a person who doesn’t trust the FDA and I’ll show you a potential shady-supplement consumer.

Sibutramine is one of the most common weight loss supplement adulterants[1]. The FDA found sibutramine in Pai You Guo, issued a safety alert to consumers, and recalled the product. People STILL bought it! One group of researchers tested 27 products six months after the recall and found 12 that still had the same sibutramine adulterant.

No one has ever asked me about my Product Recall Plan or Mock Recall procedure. Food companies do this pretend-recall to make sure they can account for 100% of a recalled product. If the FDA does find my product, test it, and issue a recall, I’m betting I can keep selling it. If all these other companies have gotten away with it, so can I.

CONCLUSION

I can get away with all these things as long as the consumers continue to focus on different issues. With all the mind-blowing technological advancements we’ve made as a society, we still haven’t figured out how to efficiently communicate a product recall or effectively remove known contaminated supplements from the market. If the Food Babe brought as much attention to the list of tainted dietary supplements[xiii] as she does to safe and legal food additives with multi-syllabic names, I’d be in real trouble.

REFERENCES

You can read the entire review article that inspired this post – see the first reference, below.

[i] Adulteration of Dietary Supplements by the Illegal Addition of Synthetic Drugs: A Review. Comprehensive Reviews in Food Science and Food Safety. Vol 15(1) 43-62. http://onlinelibrary.wiley.com/doi/10.1111/1541-4337.12173/abstract

[ii] Ginkgo adulteration ‘very widespread’, say industry experts, so why is awareness low? NutraIngredients-USA. http://www.nutraingredients-usa.com/Markets/Ginkgo-adulteration-very-widespread-say-industry-experts-so-why-is-awareness-low

[iii] Are You a Monster or a Rock Star: A Guide to Energy Drinks: How They Work, Why They Work, How to Use Them Safely. Booklocker.com, 2013

[iv] What is the meaning of ‘natural’ on the label of food? FDA Basics. http://www.fda.gov/aboutfda/transparency/basics/ucm214868.htm

[v] Consumers fear some ingredients more than pathogens. Food Business News. http://www.foodbusinessnews.net/Opinion/Keith-Nunes/Consumers-fear-some-ingredients-more-than-pathogens.aspx?cck=1

[vi] Global burden of foodborne diseases – Executive Summary. http://www.who.int/foodsafety/areas_work/foodborne-diseases/ferg/en/

[vii] Learning from FDA Food Allergen Recalls and Reportable Foods. Food Safety Magazine. (April/May 2014). http://www.foodsafetymagazine.com/magazine-archive1/aprilmay-2014/learning-from-fda-food-allergen-recalls-and-reportable-foods/

[viii] What Will It Take to Stop Sketchy Weight-Loss Ads? Nutritional Outlook.  http://www.nutritionaloutlook.com/weight-management-nutrition/what-will-it-take-stop-sketchy-weight-loss-ads

[ix] Chobani’s Accidental Culture War: How a yogurt lid marketing slogan pushed scientists’ emotional buttons. Chemical & Engineering News.  http://cen.acs.org/articles/92/web/2014/06/Chobanis-Accidental-Culture-War.html

[x] FDA Investigated Multistate Outbreak of Salmonella Virchow Linked to RAW Meal Organic Shake and Meal Replacement Products. US FDA Recalls, Outbreaks & Emergencies: Recalls. http://www.fda.gov/Food/RecallsOutbreaksEmergencies/Outbreaks/ucm484187.htm

[xi] Hampton Creek’s Just Mayo isn’t mayo: Regulators. CNBC: Food Products.  http://www.cnbc.com/2015/08/25/hampton-creeks-just-mayo-isnt-mayo-regulators.html

[xii] Picamilon Banned by FDA: More than Meets the Eye? PricePlow.  https://blog.priceplow.com/supplement-news/picamilon-fda

[xiii] Tainted Products Marketed as Dietary Supplements http://www.accessdata.fda.gov/scripts/sda/sdnavigation.cfm?filter=&sortColumn=1d&sd=tainted_supplements_cder&page=1