The Council for Responsible Nutrition (CRN) appreciates the American College of Physicians' commitment to protecting patients and promoting evidence-based healthcare. We share many of objectives outlined in the paper -- which appeared in the Annals of Internal Medicine -- including removing adulterated products from the marketplace, strengthening FDA oversight, improving physician-patient communication about dietary supplements, expanding nutrition research, and ensuring consumers have access to accurate, science-based information.
Where we fundamentally disagree is the paper's conclusion that these goals require replacing the Dietary Supplement Health and Education Act (DSHEA) with a pharmaceutical-style premarket approval system for dietary supplements.
The primary problems identified throughout the paper—adulterated products, unlawful disease claims, fraudulent marketing, and products containing illegal pharmaceutical ingredients—are already prohibited under existing law. These examples do not demonstrate that DSHEA has failed; they demonstrate the need for stronger enforcement against companies that violate it.
The solution is not to regulate vitamins, minerals, probiotics, and other dietary supplements like prescription drugs. Congress intentionally established a distinct regulatory framework recognizing that supplements are intended to support health, not diagnose, treat, cure, or prevent disease. Congress limited the kinds of ingredients that can be used in supplements, and it restricted the types of claims that can be made for these products. Requiring FDA premarket approval for every supplement would create an enormous regulatory burden, reduce consumer access to products with long histories of safe use, stifle innovation, and divert FDA resources away from the bad actors who pose the greatest public health risk.
CRN has long advocated for targeted modernization of the existing framework. We strongly supported passage of the 2006 Dietary Supplement and Nonprescription Drug Consumer Protection Act, a law requiring dietary supplement companies to report serious adverse effects to FDA. CRN also consistently urges Congress to increase funding for FDA’s Office of Dietary Supplement Programs to provide the necessary resources to ensure regulatory compliance and take aggressive enforcement actions against companies that intentionally violate the law. In addition, we have repeatedly called for a dietary supplement product registry as a commonsense modernization of FDA oversight, supporting congressional efforts – including the recently introduced Dietary Supplement Listing Act of 2026. These practical reforms would provide FDA with greater visibility into the marketplace and strengthen its ability to identify and remove illegal products without disrupting responsible manufacturers or limiting consumer choice.
We also agree that healthcare providers should routinely discuss dietary supplement use with patients, and we support additional investment in nutrition research and better education for both clinicians and consumers. But misinformation and fear mongering directed toward a category of products that enjoys a tremendous legacy of safe use only shut down productive conversations between patients and their healthcare providers. Companies making deceptive claims or marketing adulterated products should face swift action from both FDA and the Federal Trade Commission.
Ultimately, the choice is not between today's regulatory framework and pharmaceutical regulation. It is between targeted modernization that strengthens FDA's ability to enforce the law and a sweeping overhaul that would burden responsible companies while doing little to deter those already operating outside the law.
CRN remains committed to working with policymakers, healthcare professionals, and regulators to modernize dietary supplement oversight through balanced, science-based reforms that protect consumers, preserve access, and strengthen confidence in a responsible industry.
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The Council for Responsible Nutrition (CRN), founded in 1973 and based in Washington, D.C., is the leading trade association representing the dietary supplement and functional food industry. Bringing together manufacturers, ingredient suppliers, and service providers, CRN unites its member companies around a shared commitment to science, transparency, and responsible business practices—advancing a strong, credible marketplace that supports consumer health and industry growth.
In an increasingly complex regulatory and media environment, CRN serves as the industry’s front line—shaping science-based policy, defending market access, and countering misinformation. Through strategic advocacy, self-regulatory leadership, voluntary guidelines, and evidence-based communications, CRN ensures that responsible companies are recognized, protected, and positioned to innovate and compete. Learn more at crnusa.org and follow @CRN_Supplements on X and LinkedIn.