The Council for Responsible Nutrition (CRN) has issued comments on econiomically motivated adulteration (EMA) in the dietary supplements industry, per Docket No. FDA–2009–N–0166.
In its comments, CRN acknowledges that EMA is a serious and growing concern for all consumer products industries, observing that the combination of key ingredients or raw materials that are in relatively high demand but relatively low‐supply leads directly to this practice.
CRN obseves that "inadequate ingredient supplier qualification, especially among the smaller and less experienced dietary supplement manufacturers, coupled with the fact that ingredient suppliers are not subject to the dietary supplement GMPs, can be a contributor to sustaining a climate of EMA", leading the association to suggest that proper supplier qualification (perhaps through SIDI), in the absence of clear guidelines from FDA, be an industry-led effort, although FDA enforcement and perceived consequences for crinminal behavior are also critical. CRN also suggests a more active approach on the part of industry to inform FDA of known incidences of EMA.