Effective Date of AHPA Trade Recommendations Nears

(Silver Spring, MD) -- This past March, the American Herbal Products Association adopted two new trade recommendations: one regards potential adulteration of black cohosh (Actaea racemosa), the other requires disclosure of the presence caffeine on product labels, if warranted. Both will go into effect in one month, on September 16.

“The effective date for these two trade recommendations is drawing near,” said AHPA President Michael McGuffin. “In addition to being a membership obligation, these recommendations are driven by AHPA’s ongoing efforts to ensure the highest product quality and to promote the safe and responsible use of supplements by consumers.”

Black Cohosh Adulteration
AHPA recommends that appropriate steps be taken to assure that black cohosh rhizome and root (Actaea racemosa, syn. Cimicifuga racemosa) raw material is free of its known adulterant, Chinese cimicifuga rhizome and root (Actaea spp.).* Marketers of products that contain herbal ingredients are responsible for assuring accurate identification of all ingredients.

* Also known as sheng ma or Rhizoma Cimicifugae; consists of Actaea cimicifuga, syn. Cimicifuga foetida; Actaea dahurica, syn. C. dahurica; A. heracleifolia, syn. C. heracleifolia; and possibly other Asian species of Actaea.

[NOTE that this policy on black cohosh amends a current policy on known adulterants. See the AHPA Code of Ethics (http://www.ahpa.org/05_0700_CodeOfEthics_July2005.pdf; page 5: “Known Adulterants”) for a complete listing of herbs for which adulteration has been has been documented.]

Disclosure of Caffeine on Product Labels

AHPA recommends that dietary supplements that contain caffeine, whether as a direct ingredient or as a constituent of herbal ingredients, conform with all of the following:

1. The label of caffeine-containing** dietary supplements shall disclose the presence of caffeine in the product.

2. The label or labeling of caffeine containing dietary supplements, except for such supplements as are described in paragraph 3 below, shall disclose the quantity of caffeine per recommended serving of the dietary supplement, stated in both (1) milligrams per serving and (2) in equivalent approximate cups of coffee, where 100 mg of caffeine represents one cup of coffee.

3. The label of caffeine containing dietary supplements shall disclose the presence of caffeine but not necessarily the quantity of caffeine per recommended serving if at least one of the following conditions are met:

The caffeine containing dietary ingredient is an herb, or herbal source ingredient that is less concentrated than a 1:1 weight/weight or weight/volume concentration ratio of raw herb to dietary ingredient; or

The amount of caffeine per recommended serving of the caffeine containing dietary supplement is less than 25 mg.

4. Caffeine containing dietary supplements shall be formulated and labeled in a manner that recommends a maximum of 200 mg of caffeine per serving, not more often than every 3 to 4 hours.

5. The following or similar statement shall be included on the label of any dietary supplement that contains caffeine in sufficient quantity to warrant such labeling:

“Too much caffeine may cause nervousness, irritability, sleeplessness, and, occasionally, rapid heart beat. Not recommended for use by children under 18 years of age.”

** Consisting of caffeine and all so-called caffeine analogues that include, but are not limited to, the following terms: caffeine, guaranine, mateina, mateine, methyltheobromine, thein, theine, 1,3,7-trimethylxanthine, 1,3,7-trimethyl-2,6-dioxopurine, and 7-methyltheophylline.

AHPA’s By-Laws define “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 recommendation of the Board of Trustees constitutes an amendment to the Code. The trade recommendations described in this communication, therefore, constitute amendments to the Code and should be considered as such by all AHPA members.


The American Herbal Products Association (AHPA) is the national trade association and voice of the herbal supplement industry, the only trade association devoted solely to herbal issues. AHPA is the recognized leader in representing the responsible center of the botanical trade, and is comprised of the finest growers, processors, manufacturers and marketers of herbal products. AHPA’s mission is to promote the responsible commerce of herbal products. AHPA committees generate self-regulations to ensure the highest level of responsibility with respect to the way herbs are manufactured, labeled and sold. Website: www.ahpa.org

Karen Robin, Director of Communications
Telephone: (301) 588-1171, x-107
Email: [email protected]
Website: www.ahpa.org

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