Amazon Applies Some Quality Requirements

The gatekeeper finally gets a gate.

At last it seems that Amazon has begun to listen to the consistent requests to drive greater accountability and responsibility for the dietary supplement industry. Trust Transparency Center itself first commented on this topic and need on January 1, 2018, and since then, scores of related articles, actions, and comments have been aimed directly and indirectly at Amazon. The frustration that many of us felt at a barrier-less channel and abdication of responsibility was significant, even while proving that brick-and-mortar was the more accountable and reliable channel.

This latest Amazon action began in November 2020. Over the course of recent weeks, letters were sent en masse to many brands outlining new requirements in order to sell Dietary Supplements on the Amazon platform. Outrage and confusion have ensued, with one such active discussion demonstrating the confusion and lack of knowledge of many sellers, and exposing the reality some resellers were buying products locally from big box stores and placing them on the Amazon site:

“What is also very unclear is if only one seller will be required to submit compliance documents for a particular ASIN or each seller. If the latter, then the big supplement companies have finally found a way to kick 3rd party sellers out of the category.”

It would appear, thankfully, that this practice is likely ceasing as a result of the new requirements, and that will please many legacy brands, whose products are being redistributed.

What does the Amazon activity truly mean for in-store operations and dynamics?

Retailers may see this action as a potential threat while in reality, it will only serve the entire industry by having Amazon apply “some standards” and expectations based on product quality. While this action by Amazon is a start, there is tremendous ground to cover before the due diligence likely required by your operation is even approached by Amazon. Early indications are that the requirements, while new and relatively onerous, are not really that stringent, certainly not stringent enough to change the quality/trust equation online.

Some brands are struggling to comply with the newer requirements and some fringe players will deem the exercise not worthwhile. Online buyers will likely then choose other brands, or may in some cases decide that an in-store dialogue is the right course.

Let’s take a look at what’s truly now required from Amazon, which can be found on the Amazon Seller Central site and in the sample image below.

Image is a screenshot of Amazon's policy for dietary supplements. Requirements include a Certificate of Analysis from an ISO/IEC 17025 accredited laboratory OR product enrollment in an Independent Quality Certification Program. Product images must have a clear image of the supplement fact panel and ingredient list, have all sides of the product visible, contain name and address of the brand owner, and contain product name. The third requirement is for a Letter of Guarantee from the brand owner of the product that is on official brand owner letterhead, assures that the product is manufactured under cGMPs, assures that all ingredients are only lawful and safe, and assures that concentration of active ingredients is safe for consumption.It’s beneficial to the industry that Amazon is making some strides addressing dietary supplement accountability and reliability, but there is tremendous room for improvement to match what most of the industry already requires, including many in-store vetting programs. In fact, TTC published a simplified summary of the cGMPs required by FDA:

TTC's checklist for Online Dietary Supplement Brand Regulatory and Fundamental Compliance Checklist includes: Adverse event reporting, a retained samples program, allergen confirmation, claim substantiation, a quality control trained individual, an SOP manual, an ingredient vetting program, a label review policy, lot and expiration tracking processes, CoA verification policy, quarantine procedures, continuous training program. It also includes testing requirements: Reliability testing, third-party verified testing, stability testing, recall program including mock recalls and inspections, contract manufacturing qualifying and review audit. At the bottom of the page there is a QR code to be scanned that takes you to trusttransparency.com for details on each checklist item.This checklist highlights 17 key components all dietary supplement brands are responsible for maintaining. Many Amazon brands have (and still do) wrongfully relied on their contract manufacturers to manage the responsibilities the FDA has unequivocally stated are the brand’s own. The current online and in-market dialogue that has been the brand response to Amazon’s requirements suggest that numerous brands still don’t get it—they are reluctant to own these responsibilities.

Contract manufacturers (CM) across the country are being inundated with requests for the Letters of Guarantee (LoG) requested by Amazon. While Amazon requests that the LoGs possess the brand’s letterhead, contributors to the previously presented website thread repeatedly advise to ask the CM for the information and copy and paste it onto the brand’s letterhead. In three of the five elements of the Amazon request for the LoG, the word “assurance” is used rather than the word verification, meaning a promise from the CM is sufficient to meet the request without any support behind the assurance—missing the entire point of the GMP rule. Of the 17 items stated on this checklist, only one, third-party verified testing, is being really addressed by Amazon.

Some of the standards your organization has likely maintained for years are now coming into the Amazon expectation set as part of its seller requirements. It is clear though to all those who are still looking for compliance for all dietary supplement brands that Amazon is not complete. We do expect the Amazon requirements to evolve, but it will be some time, if ever, that they will do the thorough vetting that you can do in store. Continuing education for inquiring customers is paramount to proving your continued superior value and long-term reliability.

Note: The views and opinions expressed here are those of the author(s) and contributor(s) and do not necessarily reflect those of the publisher and editors of WholeFoods Magazine.

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