Managing Dietary Supplement Marketing Risks, with Asa Waldstein of the Supplement Advisory Group

Episode Overview

Episode Topic: Join us in this episode of NutraPreneur as we delve into the intricate world of compliance and best practices in the dietary supplement industry with Asa Waldstein, principal of the Supplement Advisory Group and founder of Apex Compliance. Discover the strategies and insights that have shaped Asa’s approach to regulatory adherence and how the Supplement Advisory Group navigates the dynamic landscape of dietary supplement regulations.

Lessons You’ll Learn: In this episode, you’ll gain insights into key strategies for mitigating marketing risks, ensuring compliance, and fostering a community approach within the industry. Learn about practical lower-risk solutions and essential elements in marketing and product labeling that not only meet regulatory standards but also enhance consumer trust. Understand the challenges and success stories encountered in implementing compliance best practices and discover the critical regulatory challenges on the horizon.

About Our Guest: Our esteemed guest, Asa Waldstein, is the principal of the Supplement Advisory Group and the founder of Apex Compliance. With a wealth of experience in the dietary supplement industry, Asa has been instrumental in guiding marketers toward lower-risk strategies, ensuring compliance with regulatory standards, and fostering a culture of regulatory adherence within the industry. Take a firsthand look at Warning Letter Wednesday and unlock the secrets of FDA scrutiny and industry pitfalls

Topics Covered: In this episode, Asa shares key strategies for crafting foolproof compliance in marketing and product labelling. Beyond the challenges, he champions a community-driven approach and spills industry collaboration secrets. A sneak peek into the Supplement Advisory Group’s regulatory game plan adds a practical touch, making compliance not just informative but an enjoyable ride for marketers.


Our Guest: Bridging Compliance & Marketing with Asa Waldstein’s Unique Perspective

Asa Waldstein is a seasoned expert and the Principal of Supplement Advisory Group, based in Boulder, Colorado. With over 21 years of experience in the dietary supplement industry, Asa is a certified Clinical Herbalist with a passion for bridging compliance and marketing. His journey, shaped by a background in herbalism and a tech-driven upbringing in Silicon Valley, led him to establish the Supplement Advisory Group. Asa’s commitment to fostering compliance involves providing practical regulatory support, identifying marketing risks, and offering lower-risk solutions for web, social media, and product labels.

In the dynamic world of dietary supplements, Asa is also the Founder of Apex Compliance, a revolutionary regulatory software launched in January 2023. This innovative tool simplifies regulatory marketing compliance, helping companies avoid warning letters and lawsuits. Apex Complianceā„¢ streamlines content review and identifies high-risk areas, reinforcing Asa’s dedication to preventive regulatory risk management.

Beyond his professional achievements, Asa is an active contributor to industry growth. As a Board Member of Naturally Boulder and Chair of AHPA’s Cannabis Committee, he actively nurtures the natural and organic products industry. As the Founder and Host of the Dietary Supplement Regulatory Education Series, Asa creates open forums for industry professionals to discuss and elevate ethical and compliant practices. Asa Waldstein’s journey reflects not only a commitment to excellence in compliance but also a deep-rooted passion for advancing the dietary supplement industry through innovation and education.

Asa Waldstein, principal Supplement Advisory Group simplifying Dietary Supplement Advisory


Episode Transcript:

Asa Waldstein: And one other item that I wanted to point out is common mistakes such as made in the USA, all-natural and the no artificial flavours and no artificial colours. These are all very common lawsuit trends, so I would do a lot of label review at Supplement Advisory Group. And these are common things that I’ll see all the time. Hey made in the USA, well, are the components from not the USA. For example, if it’s a vitamin C product, ascorbic acid doesn’t come from the USA, made in the USA. Probably something that’s going to attract attention just like all-natural and again, no artificial flavors, colors, that type of thing as well.

Bethany Jolley: Welcome to NutraPreneur the Nutra Industry podcast. I’m your host, food scientist and nutraceuticals consultant Bethany Jolley. Each episode we’ll be exploring what it takes to thrive in the nutraceutical industry. From conversations with successful nutraceutical entrepreneurs to venture capitalists to tech executives whose innovations are reshaping the nutraceuticals industry. We explore the innovations and trends that are shaping the next generation of nutraceutical businesses.
 
Welcome back to NutraPreneur, your portal into the world of cutting-edge innovations in the nutraceutical industry. I’m your host, Bethany. Today we have the privilege of hosting Asa Waldstein, the esteemed principal of the Supplement Advisory Group and founder of Apex Compliance. With his extensive experience in the dietary supplement industry and a passion for promoting compliance best practices. Asa has been instrumental in guiding marketers toward lower-risk strategies and ensuring regulatory adherence. Welcome, Asa. It’s great to have you today.

Asa Waldstein: Thank you. Bethany. Well, that intro made me sound really smart and important, but really, I’m just a passionate regulatory herbalist that kind of followed my passion for natural products into the dietary supplement industry and then into regulatory compliance. So thank you for that kind intro. Really happy to be here today.

Bethany Jolley: As someone who is also very passionate about regulatory compliance, I’m really looking forward to our conversation today.

Asa Waldstein: Wonderful.

Bethany Jolley: Do you have a rich background in developing and deploying organizational strategies in the dietary supplement industry? So could you share with us some key insights from your journey that have shaped your approach to compliance and best practice development?

Asa Waldstein: Yeah, it’s a continuingly long and wonderful journey. So I have a clinical herbalism background. I started making supplements in 2001, so I’ve really grown up in the industry. So I’ve seen the implementation of lots of regulations and laws, such as the common allergen labeling law, GMPs for supplements. So I’ve learned regulations from the inside out from a practical point of view. Also, I’ve helped oversee three FDA GMP inspections and we received no. 483. So that’s very lucky and also really cool because companies oftentimes get 483, that’s a manufacturing violation. So I grew up in the industry. And then I’ve also had the following conversation for years. Let’s say, Bethany, that we’re in a conference room or a board room, and we’re talking about our dietary supplement product, but we have to say something about it, right? We can’t just say, this product is a multivitamin, you should buy it. So what’s really informed my approach? And my consulting company today is having these conference room and board room discussions such as, hey, we have to say something about our product. We have to be truthful, not misleading. We have to have substantiation for anything we say, but we have to also get our marketing message across in a way that’s effective. So after doing that for years and years, that’s really informed me what brings me to today running Supplement Advisory Group, the consulting company.

Bethany Jolley: And I’d say Supplement Advisory Group really specializes in practical regulatory support. So how does the group assess risks for dietary supplement and hemp product brands, and what are some of the practical, lower-risk solutions you often recommend in response to the ever-changing FDA and FTC enforcement trends?

Asa Waldstein: Yeah, that’s a good one. Well, I love writing Warning Letter Wednesday. That’s a weekly post where I review interesting FDA warning letter trends that kind of forces me, and also allows me the privilege to dig deep into what companies are getting in trouble for, from an FDA warning letter point of view. So that allows me to dig deep, look underneath the hood of the nuances of what companies are getting in trouble for. Here is one example. Several years ago, maybe let’s go 4 or 5 years ago, if someone wrote a testimonial on your social media wall such as hey, Bethany’s product worked great for my arthritis and you liked it, you engaged with it, the authorities were okay or were hands off with that. But based on enforcement trends that have been reinvigorated lately, if someone writes something on your social media wall that has a disease claim related to your product or your ingredient and you like it, you say thanks, you smiley face emoji it, that’s considered endorsing the testimonial. Now, that’s just one example of how enforcement trends change. So as we look at enforcement trends, we always want to stay ahead of the curve. What are other companies getting in trouble for as a way to help inform our compliant marketing and labeling.

Bethany Jolley: Yeah. And for anyone in this industry and especially our listeners, I recommend checking out that Warning Letter Wednesday, because you can learn so much by just diving into those warning letters and seeing what the FDA is really focusing on and what people are getting in trouble for, essentially. So given the dynamic nature of regulations, how do you stay ahead of compliance challenges and ensure that marketers are equipped with the most up-to-date and effective strategies for maintaining regulatory adherence?

Asa Waldstein: So in addition to reading FDA warning letters, it’s also all the other things following litigation trends. So what are companies getting sued for? Here’s a really weird one we’re all aware of the DSHEA or FDA disclaimer these products are not intended to treat, cure, diagnose, prevent. Well, there’s actually a really upsetting lawsuit trend where some companies are getting sued for not having that DSHEA disclaimer on the same label panel as other structure-function claims. So maybe that a DSHEA disclaimer would be on the right panel, but there would be sleep support on the principal display on the main label panel. That’s a litigation trend that isn’t really talked about that much, but it’s really upsetting. So when we look at litigation trends, that kind of helps inform how we can support our clients and supplement advisory group. I also look at most of the NAD, the national advertising division cases. NAD is part of the B-b-b or Better Business Bureau, and this is where competitors can challenge each other. So for your listeners who may not know, think about the five G wars. My five G is better than your five G. Oh yeah, prove it. This is the regulatory courts, for lack of a better description, where substantiation can be brought to the surface.
 
Oh yeah, you said your five G is better. Prove it in this court. Where is your substantiation? So the supplement industry has a lot of NAD or national advertising division cases. This is really helps us understand how the national advertising division is interpreting substantiation and claims that type of thing. So we’re looking at we’re looking at of course litigation trends nad but then also guidance. Right. As we’re all aware, FTC has been busy bees over the past 11 months or so putting out the Health Products Compliance Guide, sending about 670 notice of penalty offenses to health products and dietary supplement companies. So congregating FDA warning letters, FTC action guidance talks that I have. I do a lot of regulatory discussions, a lot of public speaking, the on and off-camera talks that I have helped really inform the strategies that we like to bring forth at Supplement Advisory Group. I know that was a long answer, but that’s all the things that go in. Those are all the different lenses of which we look at regulatory compliance.

Bethany Jolley: Yeah, absolutely. And I agree with all of the new guidelines that have just been put out there by FTC. I think Supplement Advisory Group is a great resource for brands out there that might not understand all of the ins and outs of those new guidelines.

Asa Waldstein: Yeah, without a doubt. Thank you for that. And also, in addition to Warning Letter Wednesday, I’m a big fan of pay it forward. Let’s try to help one another. So on my website asawaldstein.com, there’s links to Warning Letter Wednesday, but there’s also links to my YouTube channel where there’s a lot of free how to videos. There’s links to past public speaking events such as this event will be there, so it can be a great free resource for your listeners as well too.

Bethany Jolley: Yeah. That’s amazing. And you’ve touched on it a bit, but social media and website marketing has become such a huge thing in the dietary supplement industry. And so in the context of the web and social media marketing, what are some common compliance pitfalls that marketers often overlook? And how does the Supplement Advisory Group assist in identifying and mitigating these risks to ensure that they’re regulatory compliant?

Asa Waldstein: Social media is really exciting, right? Everyone’s on social media. It’s important to every business, but there’s a lot of things that can go wrong. I’d say probably one of the most notable things, other than the liking of the post, which I’ve already talked about, is with Uncompliant hashtags. The quickest way to turn an otherwise compliant post into an uncompliant post is with the use of an Uncompliant hashtag, like hashtag arthritis. Our hashtag being silly here. So that’s pretty high level. And as we look at enforcement trends, FDA is paying more and more attention. Now, here’s one that your listeners may not be aware of. FDA is looking back many years on company social media posts. In fact, a warning letter just came out yesterday that cited a social media post. I think from 2017 that’s six years old. So that’s forgotten. Really. The only folks looking at these old posts, in my humble opinion, is probably the authorities. So we always want to be compliant with what we’re doing now. But looking back on these old social media posts, when I’m doing a when I’m doing a client intro call or a deep dive into their compliance, I’ll always go to social media, Instagram or Facebook or whatever and go back to their very oldest post and then work my way back from there, because companies may be very compliant now and learned a lot, or maybe have turnover.
 
But what about years and years ago? So looking at these old social media posts is also very important. Social sharing is a big one, so we’ll stick with the turmeric and arthritis example. Let’s say I’m a company that sells a product with turmeric in it. And if I’m sharing a clinical study, let’s say I’m sharing a clinical study related to turmeric and osteoarthritis, if I share that. On my own company social media wall that is considered marketing. Now, that’s probably maybe not going to be enforced unless the company writes something in the title like, hey, this is one of the reasons why we put turmeric in our product. Check out the study that elevates the risk. Or what about the meta description? Let’s say that the company didn’t really write any commentary, but the meta description said something like new study on turmeric and osteoarthritis. If the company sold that ingredient turmeric. In this example, just having that meta description as people are viewing this, the social share that’s considered marketing. I could talk about social media nuances all day long, influencer marketing, that type of thing. But I’ll stop there because I know we have other things to talk about. Or we can go deeper if you like.

Bethany Jolley: Yes, that was something I was going to bring up as well as with all of the influencers out there. I think it’s really important for brands to provide them with educational resources so they understand how they should be advertising their products as well, because none of them are loose cannons and you never know what they might say.

Asa Waldstein: Yeah, certainly companies always need to have a firm influencer contract code of conduct. What some monitoring, such as you can’t just bring in, or you shouldn’t just bring in an influencer and just let them do whatever they want, or have them sign a code of conduct or contract and then not do anything about it. There has to be some type of monitoring where it’s monthly or quarterly, and then some type of repercussion. If the influencer isn’t disclosing material connection, hashtag sponsored, whatever form that may be, or if they’re using unsubstantiated words, disease claims, that type of thing, there has to be something written into that contract where you’re checking on them and saying, hey, influencer, we really want you to do good. You’re a brand partner, but you can’t just keep making disease claims. I think we’ll see. In particular, FTC start to crack down more and more on influencers as not disclosing material connection, making unsubstantiated claims. And the Wild West right now, of course, is TikTok right? I like TikTok, my daughter, who’s 22, goes directly to TikTok for anything, right? Like, hey, I heard about this new hair cream trend on TikTok. I’m like, oh my God, that’s like, look at it. It’s just crazy. So there’s not a lot of enforcement happening on TikTok as related to influencers yet, but I do expect that to change in the next 6 to 12 months.

Bethany Jolley: This episode is brought to you by Nutra payments.com. If your business needs credit card processing that fully integrates with most major Nutra software platforms, offers the lowest industry prices, and has built in features like recurring billing, $0 trials, and chargeback prevention. And visit us at nutra. Payments.com for a free online quote. And something else that’s a very large part of the dietary supplement industry is the labeling aspect. So as someone who’s deeply involved in product label oversight, what are some essential elements that dietary supplement and hemp product marketers should prioritize on their labels to not only meet regulatory standards but also just to enhance that customer trust and understanding?

Asa Waldstein: So where there’s smoke, there’s fire is an adage I like to use when talking about dietary supplement labels. So let’s say that I’m looking at a website and their label is out of compliance. It’s maybe got claims on there. It doesn’t have the FDA disclaimer if it needs it. The format of the Supplement Facts panel isn’t right. Other things like that. It doesn’t have the contact information that will signal to the authorities there’s probably something wrong and trigger them to look deeper. So some common mistakes on labels that I’m seeing is with serving size. And I’m sure you know this too. Bethany with your consulting work is when we’re looking at labels. If the serving size is, for example, take 1 to 2 capsules daily or a suggested the serving size and the supplement facts panel must be that higher amount. So if it’s take 1 to 2 capsules, then the supplement fact panel must be a serving size of two capsules. That’s called out all the time. And or that’s becoming more frequent in FDA warning letters. Also simple formatting. So as we’re looking at labels and I know you know about this too, as we’re looking at labels, there’s items with the daily value percentage. And then there’s items without a daily value percentage. Items with a daily value percentage need to be above the thick line. So there’s formatting, there’s line thickness. There’s a lot of very small things that need to be on there, but they cumulatively add up to hey, let’s this label is not compliant.

Asa Waldstein: Maybe the FDA wants to go look at their manufacturing facility. It can wave a red flag. Really common mistake that I see is companies not adding their domestic street address or US phone number in the correct position on the label, so that should be underneath. The other ingredients if possible. So supplement facts panel. Other ingredients allergen statement if it needs one and then that manufactured by or distributed by. We need to make sure that customers can report adverse events. And so they do that through domestic street address or phone number on the label. Those are a couple things other than companies not adding that symbol to a structure-function claim. So we talked about this a little bit with when we were discussing litigation trends. The FDA disclaimer these statements are not intended to treat diagnosed cure, prevent disease, that type of thing. It has a symbol like an asterisk or a dagger. That symbol has got to correlate to other structure-function claims on the label. In writing Warning Letter Wednesday, I’m seeing this being called out more and more lately, especially in that next in the last month or so. So this is certainly an enforcement trend to watch. And by doing this you can lower your risk of FDA enforcement. You can also help potentially mitigate your lawsuit risk as well. There’s just a few things, but I could talk about labels all day long.

Bethany Jolley: I know there really is so much to it, and I think a lot of brands just find a really great designer that is very creative and can come up with a really nice-looking label, but then they might not understand all of the regulatory aspects, so they’re not doing the correct font sizes, they’re not creating the Supplement Facts panel correctly, as you mentioned, with the daily values at the top and the different lines and all of things, there’s just a lot to it. There really is.

Asa Waldstein: Yeah, there sure is. And one other item that I wanted to point out is common mistakes such as made in the USA, all natural and the no artificial flavors, no artificial colors. These are all very common lawsuit trends. So I would do a lot of label review at Supplement Advisory Group. And these are common things that I’ll see all the time. Hey made in the USA. Well, are the components from not the USA. For example, if it’s a vitamin C product, ascorbic acid doesn’t come from the USA, made in the USA. Probably something that’s going to attract attention just like all natural and again, no artificial flavors, colors, that type of thing as well.

Bethany Jolley: Yeah, I think we’ll start to see an uptick in that because I’ve noticed that as well, with ingredients that aren’t even grown in the US, it’ll say made in the USA, but it’s really globally sourced ingredients.

Asa Waldstein: Yeah, that’s great one as we know, made in the USA with globally sourced ingredients. If that’s accurate. That’s one potential way to to mitigate that, that risk while communicating that your products are from the USA and they also have ingredients from from elsewhere.

Bethany Jolley: Exactly. Well, I always think it’s helpful to share some success stories. So could you share with us any noteworthy success stories or challenges that you’ve encountered while helping some of these dietary supplement marketers implement compliance best practices and really just showcase your impact on the guidance of their operations?

Asa Waldstein: I love success stories and I love highlighting them, so I’ve got several recommendations on my LinkedIn profile. Asa Waldstein, LinkedIn quick plug for LinkedIn. I’m really active on LinkedIn, so hopefully we can all connect there. And then also, I’ve got all my test, a lot of testimonials at my website, my personal website, Asa waldstein.com. I love constructive feedback on ways that I can do better, but also positive feedbacks. Great. So here’s a success story that I thought about this morning. There was a large company that I contacted a year or so ago. Hey, I came across your website. There were some compliance concerns. I had gave him a proposal for helping to educate their company, reducing their online marketing risk. They decided to not go forward with the proposal. That’s fine. No hard feelings. They contacted me about eight months later and said, hey, remember those depression claims that you were talking about with our whatever ingredient it was? We just received a plaintiff attorney demand letter regarding these for those in your audience that may not know, demand letter, for lack of a more detailed description, is a pre-class action lawsuit. It’s not public. Plaintiff attorneys send out these letters. It happens all the time saying, hey, you’re doing something wrong. Settle with me for X number of thousands of dollars and we won’t cause more trouble.

Asa Waldstein: And you won’t have to pay to defend it. So demand letters are so, so common. Unfortunately. So this company received a demand letter related, I think, to their depression claims that they’re making about one of their ingredients and their supplement products, and they had to settle. They had to settle like 20 or 25 grand. And then they contacted me and said, hey, we just had to settle this lawsuit or this demand letter about something you talked about. Can we refresh that proposal? Can we hire you to come in and assess our full marketing risk? So what we did is we came in, we looked at the website. We identified essentially every risky word phrase on their website provided a detailed report on this. And then did a company training. Here’s a line-by-line playbook of everything that’s on your website that might lead to more and more lawsuits. warning letters, demand letters, whatever it may be. Here’s a lower-risk way to potentially talk about that if you have substantiation. And let’s get everybody on board to be trained in compliance. They became a really active client. And if I’m doing my job, companies call me less and less.

Asa Waldstein: So I just recently checked in with them. They’re like, hey, we’re good. We’ve just got a quick question about this, but you did such a great job. I felt that they were saying you did such a great job training us, mitigating risks. Essentially, you’ve worked yourself out of a job that’s a success story, right? Help companies build a culture of compliance. Now, we haven’t mentioned my other company, which is Apex compliance. So apexcomplianceprogram.com, that is a SaaS compliance software company because right. Running a consulting company is not enough. Let’s build a compliance software company as well too. So this launched about four months ago. Bethany. And it’s been a really big success. It essentially can find any risky word phrase on websites, videos or content before publishing. So I’ve had I’ve collected so many testimonials over the past four months from large and small companies that are using Apex to say, hey, we didn’t know that there was all these risky blogs on our website. Thanks for helping us identify them, helping us come up with a risk rating and potential lower-risk way to talk about them. So we’ve helped avoid so many warning letters and lawsuits with Apex compliance. So I find that to be a big success as well.

Bethany Jolley: Yeah. And that’s really fascinating to me as well, because it’s a very efficient approach to helping brands review their websites and things like that and blogs, and you’re able to provide them that report that just outlines everything for them and really makes it simple for them to see what’s high risk and how to correct that, which I really like.

Asa Waldstein: Yeah. Thank you. And I know that on prep for this call, we briefly ran through Apex Compliance and you provided some really great feedback in the day. In the age of AI is either terrifying or super amazing. I love AI to help bolster what we’re already doing, so we have some new AI enhancements with Apex Compliance that will make the already good, great algorithm even better. So I’m really excited for that launch here. Coming up soon.

Bethany Jolley: Yes. And your advocacy for a community approach to compliance best practice development is really commendable. How do you foster collaboration and knowledge sharing within the industry to promote a culture of regulatory adherence and risk mitigation among all of the marketers that you work with?

Asa Waldstein: Yeah. Love that. So as I mentioned, really active on LinkedIn, I do a lot of no charge events, podcasts like this, public speaking. I’m a board member and naturally, Boulder here in Boulder County where I live and always try to share knowledge, impart knowledge and build the culture of compliance. So it’s confusing, right? I mean, Bethany, I know the stuff we’ve been doing this for years, but it can be confusing for someone coming from another industry like tech or apparel or some new to supplements. The world of compliance and regulatory can be daunting. So I always I oftentimes try always to take the approach of it’s okay if you’re not an expert in compliance, but here’s a few tidbits of information about how to build that culture of compliance within a company. As I mentioned, LinkedIn very active. I spent my wife thinks I’m bananas. How many hours a week I spend building posts for LinkedIn that are just simply to support the community of compliance. So as we’re talking today, my phone’s dinging and I’m getting all these comments and engagement on my Warning Letter Wednesday post. It was just posted a little bit ago. And so it’s it’s really exciting to see people that some of them, many of them I only know through social media and online, kind of get better and better at understanding risks. I recently went to Supply Side West in Las Vegas. I spoke on a big stage about microbiome enforcement and it was so fun. But so many people came up to me and said, hey, we love reading Warning Letter Wednesday. We love your post, your public speaking. It’s really helped. Especially people new to the industry understand the nuances of regulatory compliance. And for me, that’s really heartwarming. So that’s my approach to compliance is there’s no judgment. We’re all in a learning process. It’s always continuous. And being able to add to add to this knowledge base is really quite an honor.

Bethany Jolley: Yes. And because I think a lot of people view compliance as a scary thing, or they feel like you’re just always telling them is wrong. But I think the way your approach is where you’re really educating them and you’re working alongside them to help them. So it takes that scary aspect out of it. So looking ahead to the future, what do you perceive as the most critical regulatory challenges that the dietary supplement industry might face in the near future? And how do you plan on adapting the strategies of Supplement Advisory Group to address these challenges effectively?

Asa Waldstein: There has never been a more difficult or challenging time to be a dietary supplement manufacturer and marketer. The walls are closing in. There’s plaintiff attorneys circling like sharks taking bites out of companies. As I mentioned, demand letters, that type of thing for what could be perceived as small labeling issues and all natural claims, something like that. So it’s challenging. There’s also Ada websites, Americans for Disabilities Act website, quick side quick plug for making sure your website is Ada compliant. Ada compliance is a very common plaintiff attorney. Lawsuit happens all the time, so you always want to make sure that your website is Ada compliant. This is all happening when there’s a lot of action. As we mentioned with FTC, with the Health Products Compliance Guide, the notice of penalty offense substantiating products has never been more important. So we know that we have to substantiate our products. We have to substantiate any statements we make on label or off label. All marketing is an extension of label. That’s a good mantra to keep in mind. But we’re seeing this not only substantiation not only required from an FTC point of view, but that’s bubbling over into businesses. So, for example, if you want to sell your product at Costco at Whole Foods, they’re asking for a lot of substantiation, even more than what may be required under FTC guidance.

Asa Waldstein: So it’s becoming really expensive to market dietary supplements in a compliant manner. We have to make sure we have substantiation. They’re manufactured in a correct way. We have to be cognizant about plaintiff attorney lawsuits. So as we look at these different lenses of what’s the state of the world with dietary supplement marketing and manufacturing and where it’s going, you kind of building back to your last question, Bethany, building this culture of compliance into the company. So we’re not saying, hey, we’ve launched a product. We’ve made a bunch of claims. Now let’s figure out how to substantiate them. Let’s think about this ahead of time. Hey, we know there’s regulations. We know there’s new regulations being enacted. We really want to have this risky marketing strategy that may come back and bite us. So I didn’t necessarily answer your question, but I painted the picture of state of the world of supplements. And then based on understanding the state of the world with from a regulatory and risk point of view, then we can adapt our marketing and update our marketing strategy from there.

Speaker3: Yeah, absolutely.

Bethany Jolley: And are there any upcoming initiatives or projects at the Supplement Advisory Group or at apex that you can share with our audience, reflecting the group’s commitment to continuously supporting marketers with practical regulatory solutions?

Asa Waldstein: Well, I’m on your wonderful podcast. That’s one thing. I’m also I do lots of public speaking. As I mentioned, you can go to Asa waldstein.com/appearances to see all past and future public speaking events. I’ll continue to write Warning Letter Wednesday. That’s really supportive. On the apex side, we’ll continue to make more enhancements. As I mentioned, there’s new AI powered features being being published soon and really just continuing to beat the drum of quality and compliance in a way that doesn’t turn people off with Warning Letter Wednesday. It’s everyone’s welcome. Whether you’re a dietary supplement expert, you’ve been doing this for 20 years, or you just are interested about it, or you’re a new regulatory person. So continuing on with the mission of all the public speaking, all the public initiatives having to do with Warning Letter Wednesday and then supporting Apex compliance, becoming better and better, I think that’s where we’re at.

Bethany Jolley: Yeah. That’s amazing. Well, once again, thank you so much for joining us today. It’s been a pleasure speaking with you. And as we conclude this enlightening conversation, we extend our gratitude to Asa Waldstein for sharing his invaluable experiences and insights into compliance, best practices and regulatory strategies within the dietary supplement industry. For more information on the Supplement Advisory Group’s initiatives and practical support, we encourage you to explore the provided links. Don’t forget to subscribe, share your thoughts, and join us in celebrating the ever-evolving world of nutraceutical innovations on social media. Until our next episode. Stay informed, well-nourished and inspired.

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