Supplement industry stakeholders debate mandatory product listing in the US

The reintroduced Dietary Supplement Listing Act has sparked a debate among supplement stakeholders. While the Council for Responsible Nutrition (CRN) endorses this mandatory registration with the US FDA, the Natural Products Association (NPA) strongly opposes it. 

The Dietary Supplement Listing Act would require companies to provide critical information about their products to the FDA. This includes product names, a list of all ingredients, an electronic copy of the label, allergen statements, and health and structure/function claims. US citizens can access this data through an electronic database. 

US Senator Dick Durbin says that a large share of US adults support listing requirements for dietary supplements. After proposing this legislation in 2022 and again in 2024, when it did not pass, Durbin reintroduced the act this year.

“FDA — and consumers — should know what dietary supplements are on the market and what ingredients are included in them. This is the FDA’s most basic function and the first step to protecting consumers,” says Durbin. “Americans deserve a transparent supplement market, and it’s past time that we deliver it for them.”

CRN says it has advocated for a product registry on the market for over a decade, noting that the act’s reintroduction recognizes that transparency is key to trust in a modern supplement marketplace.

However, Daniel Fabricant, Ph.D., president and CEO of NPA, counters this, asserting that the mandatory listing won’t protect consumers from bad actors or unlawful products, as that requires affirmative action from the FDA, “not more paperwork or additional laws on the books.”

DSHEA regulation

The 1994 Dietary Supplement Health and Education Act (DSHEA) gave the FDA authority to regulate dietary supplements. However, the act does not require supplement companies to register their products with the agency.

Durbin stresses that this leaves the FDA without the essential information required to understand or oversee the market.

CRN says mandatory supplement listing would boost transparency, oversight, and consumer trust without restricting innovation.At the same time, the amount of supplements on the US market expanded drastically since 1994, from an estimated 4,000 products to 80,000–100,000 products today, according to FDA estimates.

Transparency in supplements

CRN details that the new legislation would preserve the existing DSHEA framework and does not authorize the FDA to require premarket approval of supplements.

However, the Dietary Supplement Listing Act would create a comprehensive, up-to-date inventory of the vast number of supplements on the market. Lacking such a resource undermines transparency, enforcement, and consumer confidence, argues CRN.

“In an era when the administration has rightly called for more transparency about what we eat and how food is made, it makes sense to apply that same transparency to dietary supplements,” says Steve Mister, president and CEO of CRN.

“Consumers deserve to know what products are on the market and what they contain — and FDA needs that same information to do its job effectively.”

At the same time, the organization points to a 2019 survey finding that 9 out of 10 US adults favor “requiring manufacturers to provide the FDA with information about the products they sell and the ingredients they contain.”

Mister notes that a registry would strengthen consumer trust without limiting access or disrupting responsible manufacturers.

“Creating a federal registry is a transparency tool — not a barrier to innovation.”

Unduly burden

NPA’s Fabricant counters that a mandatory product listing would burden the industry with a “mountain of administrative paperwork” and warns that it would raise costs for health products.

The NPA rejects the proposal, arguing it adds costly bureaucracy, risks innovation, and does little to stop bad actors.“The Senator’s proposal also will chill investments in new dietary ingredients and make it easier for the FDA to adversely impact the availability of legitimate products in the market, based on controversial interpretations of the law and not on safety concerns.”

Fabricant notes that DSHEA already offers a comprehensive, risk-based framework for dietary supplements, arguing that the proposal will “hand bureaucrats new leverage over lawful products, cool innovation, and punish companies investing in new science and better health solutions.”

He adds that the proposal perpetuates the fallacy that labels are not accessible to the FDA and the misconception that US supplements are not already subject to FDA oversight and regulations.

“These rules include but are not limited to current good manufacturing practices, labeling requirements, adverse event reporting, and safety-related notifications to the FDA governing new dietary ingredients,” he underscores.

“Finally, NPA is perplexed that industry advocates would make mandatory product listing a priority amid the most pressing opportunities and challenges facing ingredient suppliers, manufacturers of finished products, and retailers.”

Fabricant concludes that mandatory product listing will not achieve, or even undermine, NPA’s objectives in countering threats on supplement regulation or restriction, enhancing consumer access to science-based products, ensuring the FDA moves quickly against bad actors, or addressing DSHEA’s “drug preclusion clause.”

This clause restricts supplement manufacturers from marketing ingredients that have been approved or are heavily investigated as drugs. For example, the FDA blocked nicotinamide mononucleotide from use in supplements under this clause. The FDA reversed its position in 2025 following industry action, such as lawsuits filed by the NPA.