By John Travis, Senior Research Scientist, NSF International11.05.19
Why is “clean label” so complicated?
Dietary supplement manufacturers that are looking at clean label opportunities are faced with a challenge/opportunity conundrum. There’s no regulatory definition for what constitutes clean label. That’s a challenge, especially for manufacturers that have staked their reputation on quality and safety. But it’s also an opportunity for manufacturers and brands to collaborate and create their own industry consensus definition. Questions like: “What constitutes ingredients that are ‘natural’?” and “What is the maximum number of ingredients in a product that will satisfy clean label savvy consumers?” are currently some of the issues keeping dietary supplement manufacturers (and marketers) preoccupied.
The answers to questions like these are significant to brands. They can drive manufacturing and purchasing decisions, changing revenue from black to red and back again. The risk is compounded by an absence of consumer market research. A manufacturer may not know if their label is “short and sweet” enough, or even if the listed ingredients are “simple” enough to satisfy consumers until after the company is already quite invested in a clean label product.
In addition, there are potential legal hurdles to consider. Without a regulatory body like the FDA defining the terms “clean label” or “natural,” a company uses them at their own risk. Manufacturers with a strong aversion to legal risk may decide they are better off sticking with existing regulations and industry standards, finding other ways to compete rather than adding undefined terms to their packaging and potentially opening themselves up to a legal challenge after launch.
What do consumers envision when they think about a clean label?
That’s part of the problem; ask 10 consumers what they think a clean label is, and you are quite likely to get 10 different answers. Without a widely accepted and collaborative decision on what clean label means, no two consumers are going to have the same understanding. Until then, manufacturers will continue to hear helpful yet unspecific feedback along the lines of:
not helpful.
It’s a discussion I have with my family quite frequently. We know what consumers really mean: “I don’t want ingredients that have long, complicated names, because chances are, those come from a laboratory, not Mother Nature.”
For supplement manufacturers, these unofficial clean label requirements mean manufacturers will have to find more natural sources (or use more natural-sounding names) for ingredients like preservatives, emulsifiers, and flowing agents, all of which were developed to make dietary supplement manufacturing easier and more cost-effective, and to improve shelf stability and
product quality.
How does reverting to “natural” colors and flavors impact appearance and taste? How does the use of “natural” preservatives impact shelf stability? The use of natural ingredients in place of artificial ones may impact production costs, but are consumers willing to pay a premium for a clean product?
Does this mean a manufacturer can change how they label an artificial-sounding ingredient to make it more palatable for clean label fans?
Potentially. In March 2018, then-FDA Commissioner Scott Gottlieb suggested that to help alleviate confusion between ingredients that are artificial and those that merely have artificial-sounding names, the FDA may propose more “readable and understandable” names for certain ingredients. In his examples, he cited vitamin B6, a more natural-sounding name for pyridoxine, as well as a recent petition submitted to the FDA for an alternative name for the salt substitute potassium chloride, which consumers may confuse with sodium hypochlorite, or bleach. The takeaway here is that such naming should not mislead the consumer. A deception such as that, once uncovered, could instantly destroy a brand’s reputation.
Are there specific consumer segments that are driving the clean label movement?
The impact of clean label products on consumers with dietary concerns may be of potential consequence. Consumers with food allergies have needs that can be well served with clean labels, as do those with religious dietary needs such as halal and kosher and those choosing a vegan diet. Perhaps the biggest driver of them all may be the socially conscious consumer. Care must be taken, as these impacts may not always be positive and may conflict with nutritional concerns.
How does clean label affect product certification?
Consumers are beginning to understand the possibilities of increased transparency in the product manufacturing realm, especially as it pertains to what they put in their bodies. The desire for verifiable transparency in the entire supply chain is not far off. Digital natives who have spent their entire adult lives in the age of technology may believe that data is being constantly collected by businesses and analyzed by default, even when it isn’t. And if their understanding is that data is constantly being collected and analyzed, then they also understand that it can (or believe it should) be shared, from tracking sustainability of farming or harvesting ingredients, through good manufacturing practices and, eventually, independent verification of the label claims.
Additionally, the hazy borders between ingredients verification and the realm of manufacturer claims in clean label products force certifiers to build very specific protocols, and that recalls the original issue: There is no clear-cut consensus for what “clean label” means. The need for a clean label definition is already established; a collaborative response to that need is still a long way off. And without those collaborative industry definitions, deciding what stays and what goes is a moving target; an ingredient that meets an individual manufacturer’s clean label criteria may shift into the unacceptable column rapidly and without warning.
In the meantime, certification bodies will either develop their own clean label definitions (hopefully while concurrently working to facilitate a collaboratively-developed, science-based, industry-wide version), or decide the clean label market is a too amorphous and/or risky field in which to play.
How compatible is the clean label movement with new data management technology?
As consumers are beginning to realize the possibilities of total product transparency, the demand for it will not be far behind. The possibilities are surprisingly compatible when it comes to technology and clean label. In terms of product transparency, the combination of mobile devices and automated systems creates the potential for a superstructure of information gathering, analysis and dissemination. As we place increasing reliance on technology to do the work required to keep us safe and well, it will be important to develop those superstructures in a way that analyzes the thousands of data points collected in supply chains and transforms that data into information that is easy for manufacturers and brands to share, and easy for consumers to understand and trust.
The technology is already in development (if not actual use), which will enable consumers to scan the label of a dietary supplement and track where a labeled botanical ingredient was grown, when it was grown, when it was harvested, in what country (and what specific facility in that country) it was transformed into a supplement, when it arrived at the supplement store/drugstore/supermarket, and whether the contents have been certified as authentic by independent testing.
The prospect of this heightened level of transparency may be intimidating for manufacturers and brands, but it serves their market and industry well. It may create more educated, and therefore more reliable, consumers. The near future may see the tipping point when highly transparent manufacturers and brands leverage consumer demand for reliability in clean labeling into market leadership.
John Travis has more than 20 years of experience as an analytical chemist specializing in the analysis of dietary supplements. As senior research scientist, dietary supplements, at global public health organization NSF International (Ann Arbor, MI), Travis analyzes hundreds of dietary supplement products each year for various contaminants, emerging drugs and harmful compounds. He is a subject matter expert on athletic banned substances and was instrumental in the development of the screening methods used for NSF International’s Certified for Sport program, which now screens products for more than 270 banned substances on the World Anti-Doping Agency, National Football League, Major League Baseball and National Collegiate Athletic Association lists.
Dietary supplement manufacturers that are looking at clean label opportunities are faced with a challenge/opportunity conundrum. There’s no regulatory definition for what constitutes clean label. That’s a challenge, especially for manufacturers that have staked their reputation on quality and safety. But it’s also an opportunity for manufacturers and brands to collaborate and create their own industry consensus definition. Questions like: “What constitutes ingredients that are ‘natural’?” and “What is the maximum number of ingredients in a product that will satisfy clean label savvy consumers?” are currently some of the issues keeping dietary supplement manufacturers (and marketers) preoccupied.
The answers to questions like these are significant to brands. They can drive manufacturing and purchasing decisions, changing revenue from black to red and back again. The risk is compounded by an absence of consumer market research. A manufacturer may not know if their label is “short and sweet” enough, or even if the listed ingredients are “simple” enough to satisfy consumers until after the company is already quite invested in a clean label product.
In addition, there are potential legal hurdles to consider. Without a regulatory body like the FDA defining the terms “clean label” or “natural,” a company uses them at their own risk. Manufacturers with a strong aversion to legal risk may decide they are better off sticking with existing regulations and industry standards, finding other ways to compete rather than adding undefined terms to their packaging and potentially opening themselves up to a legal challenge after launch.
What do consumers envision when they think about a clean label?
That’s part of the problem; ask 10 consumers what they think a clean label is, and you are quite likely to get 10 different answers. Without a widely accepted and collaborative decision on what clean label means, no two consumers are going to have the same understanding. Until then, manufacturers will continue to hear helpful yet unspecific feedback along the lines of:
- “A short list of a few simple ingredients.”
- “Nothing that sounds like a chemical.”
- “Nothing that looks like it has artificial colors.”
- “No artificial or synthetic ingredients.”
- “Only products labeled as organic or non-GMO.”
not helpful.
It’s a discussion I have with my family quite frequently. We know what consumers really mean: “I don’t want ingredients that have long, complicated names, because chances are, those come from a laboratory, not Mother Nature.”
For supplement manufacturers, these unofficial clean label requirements mean manufacturers will have to find more natural sources (or use more natural-sounding names) for ingredients like preservatives, emulsifiers, and flowing agents, all of which were developed to make dietary supplement manufacturing easier and more cost-effective, and to improve shelf stability and
product quality.
How does reverting to “natural” colors and flavors impact appearance and taste? How does the use of “natural” preservatives impact shelf stability? The use of natural ingredients in place of artificial ones may impact production costs, but are consumers willing to pay a premium for a clean product?
Does this mean a manufacturer can change how they label an artificial-sounding ingredient to make it more palatable for clean label fans?
Potentially. In March 2018, then-FDA Commissioner Scott Gottlieb suggested that to help alleviate confusion between ingredients that are artificial and those that merely have artificial-sounding names, the FDA may propose more “readable and understandable” names for certain ingredients. In his examples, he cited vitamin B6, a more natural-sounding name for pyridoxine, as well as a recent petition submitted to the FDA for an alternative name for the salt substitute potassium chloride, which consumers may confuse with sodium hypochlorite, or bleach. The takeaway here is that such naming should not mislead the consumer. A deception such as that, once uncovered, could instantly destroy a brand’s reputation.
Are there specific consumer segments that are driving the clean label movement?
The impact of clean label products on consumers with dietary concerns may be of potential consequence. Consumers with food allergies have needs that can be well served with clean labels, as do those with religious dietary needs such as halal and kosher and those choosing a vegan diet. Perhaps the biggest driver of them all may be the socially conscious consumer. Care must be taken, as these impacts may not always be positive and may conflict with nutritional concerns.
How does clean label affect product certification?
Consumers are beginning to understand the possibilities of increased transparency in the product manufacturing realm, especially as it pertains to what they put in their bodies. The desire for verifiable transparency in the entire supply chain is not far off. Digital natives who have spent their entire adult lives in the age of technology may believe that data is being constantly collected by businesses and analyzed by default, even when it isn’t. And if their understanding is that data is constantly being collected and analyzed, then they also understand that it can (or believe it should) be shared, from tracking sustainability of farming or harvesting ingredients, through good manufacturing practices and, eventually, independent verification of the label claims.
Additionally, the hazy borders between ingredients verification and the realm of manufacturer claims in clean label products force certifiers to build very specific protocols, and that recalls the original issue: There is no clear-cut consensus for what “clean label” means. The need for a clean label definition is already established; a collaborative response to that need is still a long way off. And without those collaborative industry definitions, deciding what stays and what goes is a moving target; an ingredient that meets an individual manufacturer’s clean label criteria may shift into the unacceptable column rapidly and without warning.
In the meantime, certification bodies will either develop their own clean label definitions (hopefully while concurrently working to facilitate a collaboratively-developed, science-based, industry-wide version), or decide the clean label market is a too amorphous and/or risky field in which to play.
How compatible is the clean label movement with new data management technology?
As consumers are beginning to realize the possibilities of total product transparency, the demand for it will not be far behind. The possibilities are surprisingly compatible when it comes to technology and clean label. In terms of product transparency, the combination of mobile devices and automated systems creates the potential for a superstructure of information gathering, analysis and dissemination. As we place increasing reliance on technology to do the work required to keep us safe and well, it will be important to develop those superstructures in a way that analyzes the thousands of data points collected in supply chains and transforms that data into information that is easy for manufacturers and brands to share, and easy for consumers to understand and trust.
The technology is already in development (if not actual use), which will enable consumers to scan the label of a dietary supplement and track where a labeled botanical ingredient was grown, when it was grown, when it was harvested, in what country (and what specific facility in that country) it was transformed into a supplement, when it arrived at the supplement store/drugstore/supermarket, and whether the contents have been certified as authentic by independent testing.
The prospect of this heightened level of transparency may be intimidating for manufacturers and brands, but it serves their market and industry well. It may create more educated, and therefore more reliable, consumers. The near future may see the tipping point when highly transparent manufacturers and brands leverage consumer demand for reliability in clean labeling into market leadership.
John Travis has more than 20 years of experience as an analytical chemist specializing in the analysis of dietary supplements. As senior research scientist, dietary supplements, at global public health organization NSF International (Ann Arbor, MI), Travis analyzes hundreds of dietary supplement products each year for various contaminants, emerging drugs and harmful compounds. He is a subject matter expert on athletic banned substances and was instrumental in the development of the screening methods used for NSF International’s Certified for Sport program, which now screens products for more than 270 banned substances on the World Anti-Doping Agency, National Football League, Major League Baseball and National Collegiate Athletic Association lists.
