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FDA warns drug manufacturer marketing CBD products

Warning letter and cup of coffee

For the fourth year in a row, FDA delivered at least one warning letter related to the sale of cannabidiol (CBD), reflecting the agency’s concerns that the cannabis-based compound features claims documenting an intent to treat diseases such as cancer and schizophrenia without necessary drug approval.

FDA also reiterated its position that CBD cannot be lawfully sold as a dietary supplement because, in part, it has been subject to substantial clinical investigations held by GW Pharmaceuticals plc.

warning letter was sent to Signature Formulations LLC on July 31, 2018, a little over a month after FDA approved Epidiolex, a CBD drug manufactured by GW Pharmaceuticals used to treat seizures associated with rare forms of epilepsy typically occurring in early childhood.

In addition to raising concerns over the marketing of CBD products, FDA cited Signature Formulations for “significant violations of current good manufacturing practice (cGMP) regulations for finished pharmaceuticals.”

Based on a review of a product label for “CBD Muscle Gel” and a website where Signature Formulations markets various CBD products, FDA determined the claims established the products are unapproved new drugs.

Among the website claims quoted by FDA:

“For hundreds of years, people have used preparations made from C. Sativa, including CBD for a variety of disorders, including gout, rheumatism, malaria, pain, and fever.”
“[P]eople have reported reduced pain or positive results from taking CBD as a dietary supplement for ailments and neurological disorders such as . . . Alzheimer’s Disease . . . cancer . . . Crohn’s disease . . . diabetes . . . fibromyalgia . . . glaucoma . . . gout . . . HIV dementia . . .. . . Parkinson’s disease . . . rheumatism . . . schizophrenia . . . stress disorders like PTSD [post-traumatic stress disorder] . . .”

Signature Formulations did not immediately respond to an emailed request for comment.

In phone interviews, two lawyers who advise clients on FDA regulations said they were unaware of a warning letter sent to a company solely because it marketed CBD.

Previous letters, New York-based attorney Marc Ullman said, targeted “products making drug claims” and were consistent with a statement from FDA commissioner Scott Gottlieb, M.D., which “indicated the agency, at this point at least, is going to exercise enforcement discretion and act against the products that are making unapproved drug claims.”

Said Justin Prochnow, a partner in Denver with Greenberg Traurig LLP: “If you’re going to dip your toe into the CBD waters, at the top of the list should be, ‘Don’t make disease claims.’”

According to FDA, all CBD products sold as supplements are noncompliant, added Ullman, of counsel to Rivkin Radler LLP.

“But they [FDA officials] are using their discretion for now and acting only against the products making illegal drug claims,” the attorney said. “The thing about enforcement discretion is they could change their mind tomorrow and they are not required to give any advance notice. They can change their mind tomorrow. They can change their mind in five years.”

The warning letter, Prochnow suggested, serves as a reminder that FDA hasn’t changed its position that CBD is not a permissible ingredient in a dietary supplement. The lawyer also pointed out FDA hasn't gone beyond warning letters in its enforcement strategy related to CBD.

"While the FDA has reiterated its position on the legality of CBD in various forums, the FDA has also emphasized that its focus is on safety issues and those companies making disease claims regarding their products," Prochnow explained in a follow-up email. "To date, the FDA has not taken any further steps to enforce its position that CBD is not a permissible ingredient."

The issuance of additional warning letters, Prochnow opined, is unlikely "to change the behavior of many companies selling products with CBD in them."

That's because he said many companies have interpreted FDA's message as so "long as a company doesn’t make express disease claims, the FDA is unlikely to take action and, even if a company is making disease claims, the only repercussion is likely to be a warning letter in the file."

Editor's note: Looking for an in-depth look at the current landscape of CBD and strategies to mature it as an industry? Join us for the CBD and Hemp Extracts: How Do We Move Forward? workshop on Wednesday, Nov. 7, at SupplySide West 2018. This workshop is underwritten by CFH, CV Sciences, Elixinol, KGK Science, Neptune Wellness Solutions and RAD Extraction & Processing.

[email protected]: The Amazon effect boosts Boxed | Food halls see resurgence

Boxed Boxed delivery

Amazon’s ripple effect on grocery industry: Rivals stock up on start-ups

One of Japan’s largest retailers, Aeon Group, has invested $110 million in Boxed, an online company that sells and delivers bulk grocery items. It’s the latest move in a flurry of grocery e-commerce activity spurred by Amazon’s purchase of Whole Foods Market last year. Read more at The New York Times


Food halls are the new food truck

Food halls have been around for more than a century, but modern conveniences and innovative marketing are boosting their popularity. Gotham West Market opened in Manhattan, New York, five years ago. Across the country, the number of food halls increased to 118 in 2017 from 70 in 2015. Food halls are increasingly common in suburban mixed-use developments, as they offer convenience and variety for consumers, and help operators keep costs down. Read more at


Guest voices: Straw man solutions for sustainable supply chains

Add The Walt Disney Co. to the list of companies eliminating plastic straws and drink stirrers at all of its restaurants around the world. As other companies have, the decision was described as “another important step in our journey of environmental stewardship.” Yossi Sheffi, director of the Massachusetts Institute of Technology’s Center for Transportation & Logistics, argues that banning straws will not make a difference in the amount of plastic that enters the oceans. Read more at The Wall Street Journal


Opinion: How I learned to face food waste and plan smarter

Reducing your personal volume of food waste requires more than good intentions. Carolyn Beans, a mother of two and a science journalist, set out to reduce her family’s food waste—no small feat with a baby and a toddler in the home. She shares how she did it and what she learned. Read more at NPR


Ontario coffee chain Second Cup may pivot to pot, as marijuana goes legal in Canada

A Canadian chain of coffee shops might instead begin selling marijuana next spring. Second Cup says it’s considering changing about 130 stores in Ontario, Canada, to retail marijuana outlets. Legal sales of marijuana for recreational use are scheduled to begin on Oct. 17. Read more at Fortune

Health food pioneer, restaurateur Bill Galt dies at 89

Courtesy of William Galt Jr. William Galt with Good Earth restaurant sign

Bill Galt, a health food pioneer who founded Good Earth Restaurants Inc. in 1975, died on Aug. 2 at the age of 89.

The Associated Press reported that Galt died in Reno, Nevada, from complications after surgeries to repair a broken hip and pelvis.

His son, William Galt Jr., told New Hope Network Content Director Christine Kapperman in an email, “He loved your organization, and attended Expo West every year including this year.”

Bill Galt was an early franchisee of Kentucky Fried Chicken and a close friend of KFC founder Colonel Harland Sanders, according to his son. (In the undated photo at left, Bill Galt and his first wife, Nancy O’Donnell Galt, review a brochure with Sanders.) Galt went on to own other restaurants in Reno, serving barbecue beef and fish and chips. He reconsidered his offerings as he saw many restaurateur friends dying of heart attacks in their 40s, and Sanders himself suggested that Galt open a restaurant that served healthy food.

In 1975, he opened a 22-seat restaurant in Reno: the first The Good Earth, with the goal of changing the eating habits of Americans. The restaurant offered only fresh, unprocessed foods, many of which were plant-based. Galt researched cultures worldwide to learn about the food they ate.

When the 30th location of The Good Earth opened in Honolulu, Hawaii, Advertiser Food Editor Mary Cooke wrote, “He made chain-restaurant culinary magic with beans and greens and grains and breads; fruits and vegetables in season; nuts, cheeses, yogurt, butter and sherry; moderate portions of fish, fowl, eggs and beef; creative sauces and seasonings that range from the exotic to the down-home.”

Galt noticed the relationship between mental health and diet when he was a nutrition consultant for a mental hospital, Cooke wrote. She quoted him saying, “We saw the harmful effects of sugar, especially on the schizophrenics, and many times we saw them clear up when their diet was changed.”

After a stint in politics, Galt believed he wasn’t making the world a better place. Through his studies, he came to believe that nutrition and world health were connected to war.

“I decided that the best way I could make a real contribution was to be a catalyst in changing the nutrition habits of the world,” Galt told Cooke. Galt’s daughter, Marialice Galt, managed the Hawaii restaurant after she earned college degrees in nutrition and criminal justice, he said.

General Mills purchased The Good Earth chain of 15 restaurants in 1980, but Bill Galt continued to be the chain’s chairman.

By 1986, General Mills had converted some of the 20 company-owned locations into Olive Gardens or Red Lobsters and closed others. Other locations were operated by franchisees, according to the Los Angeles Times.

“Good Earth is probably the most prominent chain example of a health-food concept,” Richard Martin, West Coast editor of Nation's Restaurant News, told the L.A. Times in March 1986.

Galt is survived by his wife of 28 years, Gail Weaver; his former wife, business partner and mother of his children, Nancy O’Donnell Galt; his children, Marialice Galt, Lisa Galt, William Galt Jr. and Nancy Galt Jr.; and his two grandchildren.

All photos courtesy of William Galt Jr.

Natural Products Expo

What are the NEXTY Consumer Choice Awards?

Package delivered to doorstep

The NEXTY Consumer Choice Awards are a branch of the NEXTY Awards program, introduced first at Natural Products Expo East 2018 and continuing at every Natural Products Expo since then. 

During the call for nominations, exhibitors apply to have their product shipped to 1,000 targeted consumers who then sample the product and provide ratings and feedback through an app. Brands can apply within three categories: Food and Beverage, Personal Care and Natural Living, and Supplements. Only exhibiting brands can apply and the product must meet New Hope Network standards and be a product that will be shown at the exhibitor's booth.

New Hope partners with Sampler for technology and shipping fulfillment. Consumers enter the program as subscribers of health-focused media partners. Consumers who are a match for the brand’s desired target market receive a product sample and are asked to fill out a short survey after a 30-day period of testing the sample at home. Consumers weigh in on whether they would purchase the sample after having tried it, and whether they believed the product was healthy, innovative and inspiring. Consumers also provide feedback on how the product could be improved. Based on consumers’ responses and a scoring algorithm, products receive a NEXTY Consumer Choice score that ranked them against other entrants in their category.

Participating brands receive access to their scoring dashboard during and after the campaign where they can see consumer participant demographics, as well as the consumer feedback and ratings. The cost to participate in the NEXTY Consumer Choice Awards varies and 1,000 samples need to be delivered to the Sampler fulfillment center.

Natural Products Expo

Next in natural: The Natural Products Expo East 2018 NEXTY Award finalists

Twice a year New Hope Network and industry judges gather to celebrate the newest innovations coming from the brands driving the natural products industry forward. This time, we’ve chosen 57 impressive products as finalists for the Natural Products Expo East 2018 NEXTY Award program.

From a record number of nominations, New Hope Network editors and Sterling-Rice Group staff narrowed down more than 450 nominated products to a pool of 57 finalists across 22 categories. This time, we added two new categories to better represent what we’re seeing in the marketplace. New category additions are Best New Tea or Coffee and Best New Ready-to-Drink Beverage. Two to four finalists were chosen per category, depending on the number of total entries for the category. 

In addition to the 57 products that wowed us, we’re recognizing six finalists for our NEXTY Consumer Choice Awards—a new branch of the NEXTY Award program that entails brands applying to have their product shipped to 1,000 targeted consumers to receive product ratings and feedback. Learn more about the new Consumer Choice Awards.

Only one product per category will be awarded a coveted NEXTY Award, to be presented to the winners at brand booths on Friday, Sept. 14. We’ll also award six Editors’ Choice NEXTY Award winners that will be selected on-site.

Here are this year’s finalists.


Please point me to the vitamin D cartel

Karen Howard CEO and Executive Director of  ONHA

Sunday’s The New York Times included a piece written by Liz Szabo entitled, "Vitamin D, the Sunshine Supplement has Shadowy Money Behind It."  It’s another jab at the value of nutrient supplementation, claiming that BIG money has created unnecessary demand for vitamin D testing, biased research and unjustly impacted physician practice patterns. The article includes a Kaiser Health News Investigation—prepared specifically for The New York Times—alleging Dr. Michael Holick, a highly regarded vitamin D researcher, has “used his prominent position in the medical community to promote practices that financially benefit corporations that have given him hundreds of thousands of dollars.” What an interesting perspective; using the most common of my criticisms about pharma research and funding to go after a nutrient that costs maybe $100 a year. You have to wonder why some folks, and Kaiser, have it in for a hormone that plays such a central role in the human body. It turns out, this is not the first rodeo for Szabo and Kaiser.

In a Facebook Live interview on Kaiser Health News, (you can skip to minute 19:37) Szabo makes some rather bizarre statements, claiming while the American diet is awful and we consume too many calories, “we’re overnourished.” “We’re not,” says Szabo, “vitamin deficient. Our food is really, really fortified.” According to Szabo, when you drive through a burger joint, your chocolate milkshake is fortified with vitamin D, the white bread hamburger bun is a source for B vitamins and “even the salt poured onto your french fries is gonna have iodine.” She continues, “Even though our diet is really, really horrible in so many ways, it’s not low in vitamins,” and concludes her interview by marveling at the vitamins contained in Fruity Pebbles, Capt’n Crunch and Frosted Flakes. Interesting perspective on 1) what constitutes food, defined as nutritious substance, and 2) the definition of nutrition itself, aka iodine from french fries.

Where’s the money?

Is money corrupting vitamin D research?  I cannot speak to the undocumented claims Dr. Holick has financially benefited, other than to say the author’s assertions are apparently rooted in Holick’s own financial disclosures.  I can cite a fully documented example of Medicare cost increases because of corporate influence. CNN reported in June that drugmakers Mallinckrodt and Questcor, which make H.P. Acthar Gel, a drug best known for treating a rare infant seizure disorder, paid 288 practitioners more than $6.5 million for consulting and promotional speaking between 2013 and 2016. Medicare spent nearly $2 billion on Acthar from 2011 to 2016, (almost $1.8 billion of which was spent from 2013 to 2016) according to the Centers for Medicare and Medicaid.  Some doctors say an equally effective treatment would have cost a tiny fraction of that amount.

Szabo says physicians ordered more than $10 million of vitamin D tests for Medicare patients, an increase of 547 percent since 2007, for a cost of $365 million. That breaks down to $6.47 per Medicare beneficiary. I haven’t yet met anyone getting rich off of vitamin D.

Note: For Medicare beneficiaries, screening tests are governed by statute. Vitamin D testing may not be used for routine screening. Once a beneficiary has been shown to be vitamin D deficient, further testing is medically necessary only to ensure adequate replacement has been accomplished. Thereafter, annual testing may be appropriate depending upon the indication and other mitigating factors. 

Dare we challenge the status quo?

Szabo writes Holick challenged “the prestigious National Academy of Medicine (then known as the Institute of Medicine), a group of independent scientific experts” who concluded most Americans get enough vitamin D naturally and the blood serum levels of 20 ng/ml and above were sufficient. Dr. Holick and colleagues concluded in the peer-reviewed  Journal of Clinical Endocrinology & Metabolism, deficiency is common in all age groups, and the Endocrine Society subsequently issued a statement asserting vitamin D levels need to be at least 30 ng/ml. Who’s right? 

Note: The prestigious IOM made a mathematical error.  When concerns were raised about potential mathematical errors in the IOM vitamin D report that could have led to recommended intakes being set too low, the National Academies of Science, Engineering, and Medicine (NASEM) convened expert panels to review the issue in two phases. The phase one expert panel was asked to determine whether or not statistical errors were indeed present. The conclusion was yes. This triggered establishment of a second phase panel review of four, two of whom were also on the original 2011 IOM panel that made the original recommendations. This panel was charged with determining if and how the IOM report's recommendations should be changed in light of the errors identified. The second panel concluded the errors found would not change the final recommendations. I want to take that math class!

We must move forward

O&N has filed a health claim petition with the FDA that higher levels of vitamin D reduce the rate of preterm birth. In fact, having a vitamin D blood serum level of 40 to 60 ng/ml reduced preterm birth rates by 60 percent at the Medical University of South Carolina, where virtually all of the practitioners had low vitamin D levels themselves. There were no adverse effects from vitamin D. New research shows that women over the age of 50, with blood serum levels of 60 ng/ml or higher have an 80 percent reduced risk of breast cancer. 

We are challenging the status quo and asking the scientific community to consider how measuring nutrient levels, not dosage, is a better evaluation tool for study outcomes. Yes, we are challenging the "gold standard." Remember, RCTs are designed to measure the effectiveness and safety of a foreign object (drug) entering the body. Nutrients are not foreign, nor can you double-blind participants and forbid they eat food.  We owe it to the public to demonstrate the effectiveness of nutrient supplementation. Otherwise, they’ll continue to be subject to the whims of press reports and the scary certitudes of Szabo who believes “if you never get a cold, it’s because you don’t smoke.” 

Signed, Aspiring Member of Vitamin D Cartel

Have some big ideas or thoughts to share related to the natural products industry? We’d love to hear and publish your opinions in the IdeaXchange. Contact the editor at [email protected] for more information.

Natural Products Expo

7 apps for Natural Products Expo East ease

apps for Expo West

Charge up your phone, pack extra battery power and prepare to charge through Natural Products Expo East with these winning apps that will help you before the show, on the floor, after a busy day and when you return home.

Keep your travel itineraries in one convenient place with the TripIt app. Connect it to email and the app imports flight, hotel and shuttle confirmations, and other travel documents automatically. You can manually add notes, maps and other useful information, too.

This is a must-have on my phone.

It’s free, but if you pay for TripIt Pro, you receive more integration from airports and airlines.

Ride-sharing services might not be an everyday part of your life, but they are essential if you plan to venture far from the Baltimore waterfront. Download the apps now and get your accounts set up before you arrive in Maryland. You don’t want to waste time (and your data service) standing on a sidewalk fumbling with a-new-to-you service.

Lyft is generally cheaper than Uber, but both raise fares during high-demand times (such as when a lot of people come to town for a convention). It’s worth comparing.

The promo code HiFreeRide will get Uber newbies a free ride (up to $15). And referrals earn you $5. Lyft’s sign-on bonuses are a bit more detailed.

The Expo East app
The Expo East app includes all the necessities—campus map, exhibitor list, education and events schedules, etc. But it also serves as your one-stop resource for schedule planning, note taking, getting walking directions to a booth and accessing all the contact info you need for a brand. Search by brand or preplan your route and let your fingers do the walking with the map—just zoom in and click on a booth to get the company lowdown. You can add it to your faves and/or agenda and save any notes you need before you get there or take while visiting on the show floor.

Search “Expo East” in the app store.

If you haven’t adopted Evernote, now’s the time. The note-taking desktop and mobile app makes capturing notes easy and accessing them anywhere a breeze. Start a note and type away. And right on the note file, you can easily add photos, record a conversation or comment to yourself, make a sketch or attach additional files.

Consider a note for each booth you attend, or capture thoughts and snapshots by time or convention center area and then organize all the info when you get home.

Combine the Scannable app with Evernote and you have the ultimate virtual filing cabinet. You can use Scannable on its own to capture sales sheets and other documents for saving in Evernote or other apps, and to share with others. Best of all, you can scan a business card and it creates a contact file.

Terrible at capturing business receipts on the road? Use Scannable. Sure, you can take pictures of such things, but Scannable straightens, sharpens and makes everything a readable file. It even works well for multiple-page documents.

Relax Melodies
You will likely return to your hotel room exhausted and ready for sleep. But if you can't turn your mind off after a great day of networking and dealing on the show floor, try Relax Melodies. Set the timer, mix your perfect relaxing track and let the music move you to la la land. Sleep meditations may be useful too.

Natural Products Expo

Expo East 2018 trend preview: Healthy snackification

Snacking Promo

U.S. sales of salty snacks alone are expected to reach $29 billion by 2022, according to Packaged Facts—and that figure doesn’t even include the sweet bites, balls and bars that are flying off natural store shelves. With these Natural Products Expo East snack launches permeate all sections of the store, including frozen, refrigerated and grocery.

Rind Tropical Blend
Did you know that more vitamins, antioxidants and fiber are found in the skin of fruit than in the flesh? We needed this gentle reminder. Rind launched to make sure health-conscious consumers get their fruit skin in by drying thinly sliced oranges, apples, kiwis and persimmons without first removing the skin. The result is a healthful snack that delivers 7 grams dietary fiber per serving, and a cool food waste-mitigation story, as no fruit skin peelings head to the landfill from this facility. SRP: $5.99; Booth 262

Taali Water Lily Pops Tangy Turmeric
Popped water lily seeds are a popular snack in India, and have a long history of being used as an Ayurvedic medicinal food. But they are relatively unknown in the United States. Taali hopes to change that by offering popped lily seeds in both classic and consumer-friendly flavors, such as Tikka Masala, Sriracha Spice, Tangy Turmeric, Himalayan Pink Salt and White Cheddar. They are delightfully crunchy, and even deliver a touch of protein. SRP: $3.99; Booth 860

I’m Different Original Crunchy Coconut Clusters
These crispy snack chunks feature sweetened coconut, pumpkin seeds, chia seeds and whey protein concentrate for an added boost. Each serving contains 6 grams of protein—impressive for such a small snack. We particularly love how I’m Different rocks a hard-core 80s vibe with its packaging—it’s sure to stand out on the store shelf! High-fives to the Non-GMO Project Verified seal, too. SRP: $5.99; Booth 4704

Nolita Cauli-Bites Original
Remember those frozen tater rounds you used to eat in high school? These delicious frozen “cauli-bites” are much better! Made not with potatoes but with cauliflower, these crunchy baked orbs are a fun side dish or quick snack. To serve, just pop them into the oven, and allow to turn golden brown. Followers of grain-free diets should rejoice, too, as cauli-bites are made with almond flour, not wheat flour. So tasty! SRP: $8.99; Booth 9020

Lavva Original Whole Food, Plant Based Yogurt Mango
We’re not exactly sure how Lavva founder and CEO Liz Fisher made this plant-based yogurt so texturally similar to dairy yogurt, but we’re excited that she did. The secret to this yogurt’s success is the pili nut, a rich, buttery nut that is cultivated in volcanic soil in Southeast Asia, cassava root and plantains. Lavva earns bonus points for this product because the formulation doesn’t contain added sugar, just fresh mango. SRP: $2.49; Booth 5100

Shanti Bar Mango Cashew Turmeric
This ultra-clean nutrition bar is a USDA Organic delight. Shanti Bar stands out in the crowded bar market for containing 17 grams high-quality plant-based protein from a blend of high-quality sources, including brown rice, cashews, almonds and chia seeds. Goji berries, turmeric, mango and cacao butter give this bar superfood status. SRP: $2.99; Booth 8821

Natural Products Expo

5 wellness products to check out at Natural Products Expo East

Wellness Promo Image

The idea of the “wellness” has permeated the natural industry, and general consensus suggests that the unofficially defined term means an optimization of all parts of life. Products that target sleep, skin care mood and even feminine hygiene work synergistically to improve overall health.

SOM Sleep Zero Sugar
The impetus for launching this innovative brand was when CEO and Co-founder John Shegerian fell asleep at the wheel and almost crashed—a scary experience that prompted him to make a beverage that encouraged deeper, more restorative sleep. Drink this 8.1-ounce can 30 minutes before bedtime and the active ingredients including magnesium, vitamin B6, GABA and L-theanine will lull the drinker to sleep. A bit of melatonin will help knock one out when occasional restlessness really takes hold. SRP: $2.99; Booth 5203

Satya Kama Cream OG
This luxurious, thick body cream is crafted with food-grade, plant-based ingredients perfect for nourishing stubbornly dry skin. Inside you’ll find shea butter, cocoa butter, coconut oil, avocado oil and hemp seed oil—ingredients that melt into the skin. We love how Satya lists its core beliefs, which include upholding truth and non-violence—and walks the walk with a Certified B Corporation distinction and 1% For The Planet membership. SRP: $30; Booth 6566

LifeSeasons Mood Uplift-R
Science meets wisdom in this quality formulation designed to promote balance and calm. L-theanine, L-tyrosine, 5-HTP and B vitamins normalize nerve transmission, while saffron, rhodiola, lemon balm, passion flower and ginkgo help nourish and promote circulation. The result is a supplement that helps normalize the aspects of the nervous system and endocrine system that influences mood. SRP: $39.99; Booth 3953

Redd Remedies Curcumin T4
The Curcumin C3 Complex ingredient contains only the core inflammation-regulating power of turmeric. The adaptogen king ashwagandha is awesome for stress response, and a trio of TCM herbs—corydalis, phellodendron and cang zhu atractylodes—are quite unique. The three support harmony between the body and mind and keep the chi moving throughout your body. All in all, a solid four-step plan for support of joints, muscles, the brain and the stress response. SRP: $34.99; Booth 3319

Organic Initiative Organic Cotton Tampons with Biodegradable Applicator
Increasingly more women are growing concerned about the ingredients in conventional feminine care products—especially in tampons, because manufacturers aren’t required to disclose every ingredient inside. Organic Initiative is leading the chemical-free tampon revolution by offering tampons made with one ingredient: 100 percent organic-certified cotton. We love the cool packaging, too. SRP: $5.49; Booth 4812