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Herbal Ingredients Should Be Listed Correctly

Use AHPA's Herbs of Commerce

Herbal Ingredients Should Be Listed Correctly

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.

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