Why Marketing Natural Products is so Complicated

Part 3: The Claims Conundrum

In the previous articles (part 1 and part 2), we talked about general concerns surrounding the issues which make marketing natural products so difficult. Today we’ll talk a closer look at why we need to watch what we say.

Thanks to the rise of the natural products industry, power foods are gaining influence with shoppers who are turning health goals into lifestyle changes. Choices in the grocery aisle are now made on the overall health benefits of the product, not just on taste and price alone. This has created a rise in the number of products that are infused with traditional and medicinal herbs and spices.

The Therapeutic Benefits of Turmeric

For the past few years, turmeric (curcuma longa) has been the golden child of the spice world with its bright, beautiful hue and earthy aroma. Its also been considered the top performing ingredient in the supplement industry with sales topping the $50 million mark in 2017, a 12.2% increase from 2016.

In the mainstream channel, turmeric jumped to the fifth top-selling ingredient of herbal supplements, with sales of $32.45 million in 2017 and a 46.7% increase compared to 2016.

The golden beauty, typically used as a key coloring and flavoring ingredient in Asian cooking, has also been used as a major part of Ayurveda and traditional Chinese medicine. Curcumin (diferuloylmethane), a phytochemical found within the root is considered to be the healing compound in turmeric.

Curcumin, not turmeric as a whole, has been at the center of research and clinical studies dating back a half a century to test its antioxidant and anti-inflammatory properties along with its potential healing power. These clinical trials have addressed the safety and efficacy of this nutraceutical against life-threatening diseases in humans, including cardiovascular disease and cancer.

This has led to the spices popularity in products formulated to target inflammation as well as joint and cardiovascular health. Because of this turmeric seems to be making its way into everything from turmeric chicken bone broths to traditional turmeric teas and even a turmeric-infused chai, chocolate blended treat.

Many product formulators and marketers, all with good intentions, wonder; if an ingredient has been used medicinally for centuries, why are we restricted from talking about its natural benefits today?

Many marketers refer to scientific studies to help determine what can be said about a particular ingredient. In turmerics case, an article published on the US National Library of Medicine National Institute of Health (NIH) sites several clinical trials and the amazing benefits for curcumin. It should be noted that in many of these studies, the curcumin was combined with other agents, such as quercetin. The article also lists completed clinical trials with over 60 individual studies, all with different dosages taken for varying durations of time.

Here’s where it starts to get complicated. While one particular combination of curcumin and another compound, taken in a particular dosage, for a set period of time resulted in a positive effect on one group of people, it’s not guaranteed, or even plausible, that your product will give the same or similar result.

Not all Tumeric is Created Equal

There is also a question about potency? If curcumin is the key compound needed for a health benefit, how do we know if the potency of the curcumin is consistent with all forms of turmeric? ConsumerLab.com does a great job in answering that question in the article Tumeric Spice vs. Tumeric Supplement. To summarize, turmeric the spice is the dried, grounded root, sold as a powder. When a ½ to 1 full teaspoon (2.5 to 5 grams) is consumed it is said to have ‘certain digestive and cognitive benefits’.

It goes on to say that most clinical studies, like the ones listed above, don’t use a turmeric powder but rather a turmeric extract. The difference between the powder and the extract is the amount of curcumin found in each one.

Only 3% of the weight of turmeric powder contains curcumin while the turmeric extracts often contain concentrations of curcumin as high as 95%.

This means food or beverages containing turmeric powder will contain far less curcumin, and along with it the medicinal benefits, than a supplement which contains a turmeric extract with a high-dose of curcumin.

Consumerlabs.com takes this even further by saying that there are many supplements on the market that contains a ratio or blend of turmeric powder and extract. This can confuse a consumer as they may not be aware of how much curcumin they are receiving unless they check the dietary supplement labels active ingredient list.

Circling Back to Adulterated Ingredients

Remember in part 2 we talked about the seven brands of turmeric which were recalled for containing excessive amounts of lead. With the idea that most brands want to sell clean, healthy products, I’m sure it’s safe to say that most products producers don’t want to add an unhealthy dose of lead to the menu.

This is why it’s so important that product producers have individual ingredients tested. Third-party tests will help you determine if your product is what the supplier says it is, as well as what the potency levels are.

What Does All of this Mean for Marketers?

Understanding the potency of a particular product is important when talking about claims. A turmeric flavored broth made with the dried spice will want to make sure there is an adequate amount of curcumin per serving if they plan to sell their product with a nutraceutical benefit.

A turmeric extract supplement with a defined amount of curcumin per serving may wish to state a non-disease related benefit. This is as long as the potency, dosage and duration of use are backed by a number of clinical or scientific studies.

This is where the confusion and frustration begin for people trying to sell natural products. Yes, there are compounds found in nature that can make a positive impact on people’s lives. I am an avid supplement user and have found that certain supplements make a big difference in how I feel on a daily basis. As supplement advocates and users, we can talk about them, write about them and teach others about them. Once we decide to sell them we are taking on a greater responsibility and liability.

Healthy people eat, drink and take supplements to stay healthy. Then there are the people who are using supplements and botanicals to support mainstream medicine or are trying to ‘self medicate’. If they are sick, they will have weaker immune systems and may be on medications which could cause serious interactions with natural compounds. Healthy people may be strong enough not to feel the effects of a wrong dose, forgotten warning or drug interaction. Others may end up seriously hurt, or worse.

There is a lot of confusion and misinformation out there. For many of us, it’s a true challenge to sort through all the BS and determine the right way to market CPGs.

How we act today will define the regulations that are placed upon us tomorrow. Hopefully, additional regulations in areas that are already heavily regulated won’t be the case. [CBDs are an entirely different story.]

If you take anything away from this article, take away the fact that our industry is being watched for the purpose of protecting consumers from ‘bad actors’. Moving forward, things are going to have to change in some way shape or form. It’s time to self-regulate because if we don’t do it on our own, someone else is going to do it for us.

Disclaimer: This post is designed to provide general information on pertinent topics, and the statements are made for educational advice. If you have specific legal or compliance questions as it pertains to your products and the law, we recommend that you should seek the advice of your legal counsel, compliance expert or industry trade association for further guidance and support.

Why Marketing Natural Products is so Complicated

Part 1 of a 3 Part Series

Over the last few decades, some companies ignored the basic principles of marketing and overall consumer protection by releasing products into commerce that were deceptive, dangerous or even deadly. I’ve lost count of the number of warning letters and product recalls in the last year alone.

As a consumer, when I spend money on a product, I don’t want to worry about my health; or accidentally buying something based on a misrepresentation or an outright lie.

As a marketer, I can attest that it not only difficult and time-consuming to follow the rules but can be mind-boggling to figure out what the rules even are. While it can be exhausting and overwhelming, I understand why many of these rules exist.

Some companies sell or say anything with little regard for the physical or psychological harm they may cause someone.

They are the ‘bad actors’ who cash in at the consumers’ expense by selling products with safety issues, labeling issues and outrageous marketing claims.

They may be a small group in a growing industry filled with beloved brands who are trying to make a real difference in people’s lives. However, the negative publicity and false claims from these bad actors have diminished the credibility and reputation of a solid industry filled with reputable companies working hard to do things the right way.

It’s unfortunate, but thanks to those ‘bad actors’ we all may be facing the biggest shift in the industry since the Dietary Supplement Health and Education Act (DESHA) was introduced in 1994. This could make marketing natural products much harder than it already is.

Americans are Using Natural Products to Combat the Healthcare Crisis

Let’s look back to see how we ended up here in the first place.

I think we can all agree that America is in a health care crisis and has been for quite some time.

With 12.2 percent of all adults now lacking health insurance, that leaves almost 40 million Americans with no access to basic healthcare.

This doesn’t include the number of people with high-deductible health insurance plans who delay or deny themselves much needed preventive services, or even treatment because they can’t afford the out-of-pocket expenses.

For folks who have healthcare, it’s estimated a family of four would have spent $28,000 last year in out-of-pocket costs.

This, along with an aging population and a heightened interest in preventative health care has contributed to the rise of the natural products industry.

With many Americans left on their own to find alternative methods to get or stay healthy, they have turned to dietary supplements, functional foods and CBD products.

Companies have taken notice and cashed in on the trend by developing products that provide healthier and more cost-effective options than what was ever available via traditional methods in previous decades.

Because of this, the natural products industry is stronger than ever, having passed the $200 billion mark in 2017. Of which over half (52%) is in the dietary supplement and functional food space.

With this comes also comes an increasing number of small natural products, functional food, dietary supplement and CBD startups looking to cash in on the trend.

What Does ‘Natural’ Stand For, Anyway?

Do you know what the term ‘natural’ means?

Nothing.

According to the Food and Drug Administration (FDA), the term ‘natural’ literally stands for nothing.

This creates one of the main marketing hurdles in the industry.

With no solid rule surrounding the term ‘natural’, there is nothing that can stop a brand from slapping a leafy looking design and the word ‘natural’ on their label, as long as they can claim it’s not ‘misleading’.

With an influx of cleverly designed labels and a ‘natural’ marketing claim, we can easily confuse brands committed to creating pure products without preservatives, pesticides, harsh chemicals or carcinogens with other not-so-natural products.

The FDA has requested comments on the use of the term “natural” on food labeling in 2016, yet nothing has moved forward since then.

This creates a need for marketers to develop strong differentiation strategies focusing on product benefits. With many natural foods and supplement products containing ingredients with documented medicinal uses dating back to ancient times, it’s only ‘natural’ for marketers to want to develop campaigns based on those benefits.

This is where the rules are long and plenty, with the gist of it stating we can’t say whatever we want to say. And, if we make a claim, we better make sure we have the appropriate, i.e. credible, scientific evidence to back it up.

This is the area which many CPG marketers are wondering, how do you sell a product if you can’t say anything about it?

It’s Not [Just] a Political Issue. It’s a Public Safety Issue.

The natural products industry exists to provide alternatives to over-processed, mass-produced and unhealthy options previously provided by Big Food and Big Pharma.

Part of the growth of the industry stems not only from consumers who want products that are healthier but also from consumers who want brands to be more transparent.

Today, consumers want to know more than what’s in your product. They want to know where the ingredients and materials were sourced, how the product was made, who made it, and what the standards surrounding the production process were.

Remember those ‘bad actors’ we talked about earlier? The brands’ responsible for selling products with safety issues. These are the companies who ‘knowingly’ release products into commerce with incorrect allergen statements, high toxicity levels, adulterated ingredients, and disease-focused marketing claims. We like to call these issues – the big four. These four issues happen more often than you would think. They cause the most harm to a consumer, and to a brand’s reputation if uncovered.

The challenge is, many of these ‘bad actors’ wholesale or private label products to unsuspecting and seemingly good brands who don’t realize that they may be contributing to the problem.

Transparency is not just a new buzz word in the supply chain industry. It’s the best way to help stomp out these issues.

Pushing politics aside, regulatory agencies are consumer protection agencies. They exist to make sure regular everyday people have access to safe products in which the benefits are explained in a non-misleading manner.

Regulations are created by these agencies when a public safety issue needs to be addressed. The rules are created so people don’t get hurt.

Sometimes these regulations are easy to understand. Other times, not so much.

Regardless, if we don’t try to follow the rules, we’re going to end up with more oversight and possibly more regulations.

Expect More Enforcement for Dietary Supplements, Functional Foods and CBDs

At the close of last year, the FDA commissioner, Scott Gottieb M.D., announced the formation of a dietary supplement working group to discuss increased oversight to the industry to combat falsely labeled products, adulterated products and disease claims.

Natural Products Insider quotes Gottieb stating the reasons behind the formation of the committee is because of “concerns that the industry has gotten bigger and riskier. The FDA plans on advancing new policies to improve oversight in the space.”

While this statement alone may scare people, it is comforting to know many of the leading natural products trade associations such as the United Natural Products Alliance (UNPA), the Natural Products Association (NPA) and the American Herbal Products Association (AHPA) stand on the line between the industry and regulators.

These associations are there to ensure the FDA is tough on the bad actors, yet thoughtful about the responsible companies as layers of new regulations and quality control pressures could create problems for smaller brands.

The reality is, no one knows for sure what will happen over the next year or two.

The question is – where will that leave natural product marketers?

Selling Supplements Requires Self Regulation

Consumers have a need, and a right, to trust the integrity of the ingredients, the manufacturing process and the marketing claims for the products they consume.

For companies operating in this space, it’s essentially up to us to monitor our own self-adherence to legal, ethical and safety standards. Supplements and functional foods, unlike drugs, don’t require pre-approval to enter the market. It’s only after someone gets hurt that the FDA can have the product recalled.

Over the last few years, many brands have been following self-regulatory initiatives to improve the overall landscape and reputation of the industry.

Many larger brands who can afford to make costly changes have already contributed to the transparency movement and made big changes in their supply chain and marketing initiatives.

It’s now up to the rest of the natural product and dietary supplement product producers and marketers to educate themselves on what we can do to contribute. We all can be better at what we do. With looming changes on the horizon, now would be a good time to try.

This doesn’t end here….

We’ve talked about general concerns in Part 1 of this three-part series: “Why Marketing Natural Products is so Complicated.” While we’ve covered quite a bit, there is still a lot more to talk about. Don’t miss next weeks article, “Natural Doesn’t Necessarily Mean Safe.”

Stay tuned for PART 2.

Disclaimer: This post is designed to provide general information on pertinent topics, and the statements are made for educational advice. If you have specific legal or compliance questions as it pertains to your products and the law, we recommend that you should seek the advice of your legal counsel, compliance expert or industry trade association for further guidance and support.