Label Review Tools Part 2

By Curtis Walcker, M.S.
July 20, 2021

If you are a frequent reviewer of dietary supplement labels, you have probably found that your speed and efficiency increase when you have your “tools” readily accessible. All the way back in 2014, we published the Part 1 to this article, and are finally making good on the Part 2. The previously named tools included 1) the regulations and guidance documents, 2) a calculator for percent Daily Values, and 3) the FDA Warning Letters published weekly. Here are three additional tools to use and where to get them.

Tool #4 – Herbs of Commerce
It is pretty tough to properly label botanical ingredients without this critical reference tool. In fact, 21 CFR 101.4(h) actually requires that the common or usual names of dietary ingredients that are botanicals (including fungi and algae) be consistent with the names standardized in Herbs of Commerce. It can be purchased through the American Herbal Products Association’s website here. You will be amazed to find how many “common” names used for botanicals are not technically appropriate for labeling.

Tool #5 – FDA’s high-resolution Supplement Facts panel examples
We share the link to this tool with clients and designers maybe more than anything else. And while you must have some knowledge of required formatting and when and where to use certain formats, the FDA’s High-Resolution Examples of Different Supplement Facts Labels in the New Format is invaluable for quickly viewing a range of Supplement Facts panel types. This is a far safer model for your own labels than competitor labels!

Tool #6 – A (NEW!!) % Daily Value calculator
Although this is the same tool we recommended in the Part 1 of this article, enough time has passed that the labeling regulations have been changed, and with them came many new Daily Values and even units of measure. So once again, if you are currently using a regular calculator for determining your declarations, you are wasting far too much time. Using a program such as Microsoft Excel, you can create your own spreadsheet, where you can enter in the label values for nutrients and it will give you the percentages. A proper and efficient one will be built so that all of the nutrients are already in the order that they must be declared on the label, the correct nomenclature is used, the defined units of measure are used, and the numbers are automatically rounded to the nearest whole percentages. Not up to building one or just need a better one? Our newest version can be downloaded for a small fee here.

How Much Does Dietary Supplement Label Review Cost?

By Curtis Walcker, M.S.
February 22, 2018

Since 2013, we have set our fees based on what we feel is fair to the client. FDA label compliance review was actually the very first service we offered, and remains among the most popular. Our fee for label review has been a flat $399 per label, with usually one to three days turnaround time for years. For the vast majority of labels, this works out well for the client, but also for us. We do not experience many hagglers or complainers. In fact, we more often have people asking us why we charge so little!

This is a good question, especially as we set our fees without surveying the competitors or trying to undercut anyone. Honestly, we really did not have a clue what exactly others are charging for this service until recently. A client that chose us to review their labels shared what they found when they priced the project out with every label review company they could find with Google searching. The results were in most cases shocking, and borderline sickening in others. The insight was valuable enough that we want to share with you what was shared with us.

Comparative Pricing for Single Dietary Supplement FDA Label Compliance Review:
Competitor #1: $3,500
Competitor #2: $2,500
Competitor #3: $1,495
Competitor #4: $1,200
Competitor #5: $995
Competitor #6: $950
Competitor #7: $750
Competitor #8: $750
Competitor #9: $725
Competitor #10: $500
Dietary Supplement Experts: $399

It makes sense now why clients ask us why our prices are so low – given that we charge $399, and 10 of our competitors range from $500 to $3,500. Here are a few thoughts on what creates these discrepancies.

  1. We do not outsource or subcontract to other firms. This is a dirty little secret of the dietary supplement consulting business. We are a close knit team with very niche skills, and are very careful about who we let on the team. However, you might be surprised to know that we are subcontracted by several of our competitors for all of our services. The rates we charge them are the rates we charge you directly. Our consulting firm clients generally charge you 2-3 times that price. Ever pay $1,200 for a label review? We probably did it for your firm for $399. We won’t name names, but does you current firm have a tradeshow booth or advertise heavily? Let us quote your projects at a fair value first.
  2. Tradeshow booths, Google, and trade publication advertising is not cheap. Neither are office spaces or massive headcounts. To a large extent, we have grown by word of mouth. We invest very little in advertising, and our team works remotely. We simply do not create the overhead costs that our competitors have. We focus on making you the client satisfied, which in turn has allowed us to consistently grow year after year.
  3. We have all worked for dietary supplement companies. We know what it is like to be a start-up with a small budget. We know what it is like to receive a regular hourly wage. We trade time for money as consultants, and it is difficult to justify billing clients some of the rates we see out there. We try to balance the cost to benefit ratio to create win-win situations and clients for life.
  4. We are not lawyers! When you have legal issues, we will be the first to direct you to a legal professional that we know and trust. However, the vast majority of dietary supplement formulations, compliance, and other project types do not require a lawyer to do the work for you. And guess what, sometimes even they subcontract to consultants anyway.

Whether it be label review or any other compliance service you are looking for, we hope this article will give you some context of pricing discrepancies. Of course price should not be your prime consideration. Make sure your chosen experts know what they are doing. We always appreciate the opportunity to earn your business.