AHPA Adopts New Extract Labeling Trade Requirement, Guidance

In October 2008 the American Herbal Products Association (AHPA) adopted a trade requirement on how the word “extract” may be used in labeling of herbal ingredients, and established at that time a restriction against the use of the word extract to describe dehydrated plant materials that have not been subject to additional processing other than size reduction, such as cutting or milling. This initial policy was adopted in response to reports of dehydrated but otherwise unprocessed herbs, such as hoodia stem (Hoodia gordonii), being marketed for example as “Hoodia gordonii extract 20:1.”

The AHPA Board of Trustees voted March 11 to revise this original trade requirement to also address the use of extract ratios (such as “20:1” in the above example). The new policy therefore also prohibits the use of such ratios on herbal ingredients that are not processed by one or another extraction process. The new policy is:

Extract Labeling:

Use of the word “extract” in the labeling of herbal ingredients is not used to describe plant materials that have not been extracted with one or more solvents. In addition quantitative extraction ratios (e.g., 4:1) are not used to represent the ratio between the fresh and dried weight of an herb, or on any product that is not, in fact, an extract.

AHPA’s By-Laws defines Obligations of Membership to include “…adherence to all policies and principles of business as outlined in the Code of Ethics.” The AHPA “Code of Ethics and Business Conduct” has established that a trade requirement of the Board of Trustees constitutes an amendment to the Code. The trade requirement described in this communication, therefore, constitutes an amendment to the Code and should be considered as such by all AHPA members.

To remain in good standing, AHPA members must comply with the new trade requirement on the labeling of extracts by Sept. 11, 2010.

The Board also voted to adopt the following guidance policy on extract labeling:

Any non-liquid herbal extract* that discloses a quantitative extraction ratio stated as a ratio of two numbers (e.g., 4:1) represents the first number as the weight of starting plant material and the second number as the weight of the finished extract produced from the starting plant material. Information on the condition of the starting material should be indicated when it is fresh and may be indicated when it is dried. While adherence to AHPA guidance is not an obligation of membership, AHPA recommends members and industry follow the association’s guidelines in addition to its trade requirements.

* Federal labeling regulations require that any dietary ingredient “that is a liquid extract from which the solvent has not been removed” be identified to provide information on the “condition of the starting material,” such that such condition “shall be indicated when it is fresh and may be indicated when it is dried.” 21 CFR 101.36 (b)(3)(ii)(B).

The American Herbal Products Association (AHPA) is the national trade association and voice of the herbal products industry. AHPA is comprised of domestic and foreign companies doing business as growers, processors, manufacturers and marketers of herbs and herbal products, including foods, dietary supplements, cosmetics, and nonprescription drugs. Founded in 1982, AHPA’s mission is to promote the responsible commerce of herbal products. Website: www.ahpa.org.

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