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October 18, 2023 By: Asa Waldstein

Herbal Ingredients Should Be Listed Correctly

Takeaway -

Use AHPA's Herbs of Commerce

Listing herbal ingredients on labels in the correct format is important. This year, there have been seven warning letters that reference missing or incorrect standardized common names (SCN) on labels.

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Here are some examples.

  • Listing the name “manjishtha” is not a standardized common name (SCN), but “Indian madder” is acceptable because it’s listed in Herbs of Commerce. The Ayurvedic name for Indian madder (manjishtha) may follow the SCN in parentheses.
  • If there is no SCN in Herbs of Commerce, the Latin binomial name must be present (e.g., Phalaris canariensis).

FDA refers to the American Herbal Products Association (AHPA) Herbs of Commerce for standardized common names. This is one of the many things AHPA does to help make the supplement industry better. Thanks AHPA!

As a friendly reminder, the plant part is also needed. Interestingly, “herb” is not sufficient according to this warning letter.

From warning letter: “Your … product declares “herb,” which is not a plant part. If the entire or whole plant is used, then that information must be declared.”

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
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