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Expand Current Definition of Economically-Motivated Adulteration, AHPA Says to FDA

In comments submitted to the Food and Drug Administration (FDA), the American Herbal Products Association (AHPA) suggests the agency consider expanding the current definition of economically motivated adulteration (EMA) to include the addition or substitution of substances intended to make an adulterated material conform to existing identity and other quality tests of the genuine article.

AHPA Chief Science Officer Steven Dentali, Ph.D., presented the association’s comments and highlighted AHPA’s work on identification methods for botanicals during a May 1 meeting convened by the agency “to stimulate and focus a discussion about ways in which the food, (including dietary supplements and animal food), drug, medical device and cosmetic industries, regulatory agencies, and other parties can better predict and prevent economically motivated adulteration.”

AHPA addresses EMA in several ways, including guidance policies on known adulterants, guidance documents on topics such as the standardization of botanical extracts and marker compounds and the development of identification methods for botanical ingredients such as bilberry (Vaccinium myrtillus) fruit extract and Hoodia gordonii stem.

“EMA is much easier to predict, prevent and address when industry is intimately familiar with the commodities in trade,” said Dentali. “AHPA continues to provide important guidance with respect to EMA and other types of adulteration of botanical ingredients, supplements and other herbal products.”

The American Herbal Products Association (AHPA) is the only national trade association devoted to herbal issues. Representing the core of the botanical trade—comprised of the finest growers, processors, manufacturers and marketers of herbal products—our mission is to promote the responsible commerce of herbal products. AHPA committees generate self-regulations to ensure the highest level of quality with respect to the way herbal products are manufactured, labeled, and sold. Website:

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