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March 5, 2025 By: Asa Waldstein

Heavy Metal Contamination Leads to Recall

Takeaway -

Following specifications prevents greater issues

Following specifications prevents greater issues

High lead recall alert! A dietary supplement company in New York issued a recall for its finished product, Shatavari, due to high lead levels.

Greetings from Expo West! Today’s Warning Letter Wednesday reviews the importance of making and following specifications. Sign up for my weekly blog, which allows you to search 150+ previous posts.

The batch of high-lead products has been in circulation since 2022 and was recently tested by the Connecticut Department of Consumer Protection’s Food & Standards Division, which resulted in the recall. Thank you for finding this CDCP!

Botanicals contain “naturally occurring” amounts of heavy metals, especially in the roots, which is why ingredients and finished product specifications are required to test these items. The American Herbal Products Association (AHPA) is a good resource for understanding specifications, but keep in mind that retailers and states like California (Prop 65) may have their own requirements.

The most common warning letter violations involve specifications being incorrectly written or followed. Here are a couple of Warning Letter Wednesday posts about this.

As Warning Letter Wednesday readers know, I am not a company or product basher, which is why I typically don’t call out company names in my newsletter. I, however, always provide a link to the warning letter or case so inquisitive subscribers can explore publicly available documents. 

When I look at the recall notice in more detail, I also see labeling issues such as the Statement of Identity “Herbal Supplement” or Dietary Supplement” missing from the Principal Display Panel (PDP). This is considered a major labeling violation, and it signals deeper compliance issues to anyone who is a label reader. The adage “Where there’s smoke, there’s fire” is often true with labeling violations. 

I then ran Apex Compliance® on the company’s website and found several over-the-top disease claims. Since recalls often lead to warning letters, now is the time for this company to remove these risky marketing phrases. Also, to anyone who sells Shatavari, expect the FDA to ask about your specifications and testing during your next inspection.

Read about the joys of being a label reader while traveling (280k impressions). 

Read about the Heavy Metal Contamination Leads to Recall. 

DATE ORIGINALLY POSTED: 3/5/25

Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.

Disclaimer: The educational information provided here is for informational purposes only. Contact an attorney for specific legal advice. Rule #1 in compliance is to ensure marketing is truthful and not misleading.

Written by

Asa Waldstein
Asa Waldstein
Asa Waldstein is a 24-year veteran of the dietary supplement industry, with experience spanning manufacturing, marketing, and regulatory compliance. He is the principal of Apex Compliance, a software company dedicated to streamlining regulatory marketing compliance for the dietary supplement and natural products sectors. Asa also leads Supplement Advisory Group, a boutique consultancy focused on marketing risk analysis, labeling, and practical compliance strategies for websites and social media. Asa has helped oversee three FDA GMP inspections with no 483s and was honored with the 2023 AHPA Herbal Hero Award and the 2024 What's Up Supps Policy and Change Agent Award. He currently serves as Chair of the American Herbal Products Association’s (AHPA) Cannabis Committee, helping shape policy and industry best practices