Opposition to mandatory product listing outweighs support in AHPA member survey

Opposition to mandatory product listing outweighs support in AHPA member survey

October 2021: AHPA Update

Published: Wednesday, October 6, 2021

The Food and Drug Administration (FDA) has called on the U.S. Congress to pass legislation that would require mandatory product listing (MPL) for all dietary supplements in the United States. FDA has stated that this concept would “require all products marketed as ‘dietary supplements’ to be listed with FDA and give FDA authority to act against non-compliant products and the manufacturers and/or distributors of such products”1.

The American Herbal Products Association (AHPA) has closely monitored and discussed the concept of MPL. The AHPA Board of Trustees voted in November of 2018 to recognize that the current federal legal and regulatory framework for dietary supplements supports the supplement industry and supplement consumers, and provides FDA all of the authority needed to properly regulate lawful supplements, such that the laws and regulations do not need to be revised to include a mandatory premarket registration or notification requirement for dietary supplement products. Thus the AHPA board has refrained from supporting legislation that would authorize MPL to date, but has not adopted a position to oppose the concept either.

To understand how AHPA’s members view MPL, AHPA recently conducted a member survey on the subject. The survey included neutrally presented, equally weighted arguments commonly made in support of and in opposition to MPL. AHPA members responded to the survey and answered two questions about MPL’s potential impact on the dietary supplement market (consumers and industry) and what position AHPA should take on the issue2.

  • Approximately 52% of respondents stated that MPL would harm dietary supplement consumers and industry, and that AHPA should actively oppose MPL.
  • Approximately 18% of respondents stated that MPL would benefit dietary supplement consumers and industry, and that AHPA should actively support MPL.
  • The remaining respondents, about 30%, stated that MPL would not provide significant benefit or harm, and supported AHPA maintaining its current position to “refrain from supporting” MPL.

“AHPA will continue its engagement with industry and government stakeholders to better help all involved understand the potential costs and benefits of MPL,” said AHPA President Michael McGuffin. As a part of this process, AHPA may provide further opportunities for public discussion and debate of MPL. AHPA members wishing to participate in these activities should feel free to contact Robert Marriott at to ensure they are included.


1 From the Department of Health and Human Services FY 2021 FDA budget request.
2Results are based on Active member responses other than “I don’t know” or “I need more information”, from 72 total responses from all AHPA members.
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