There have been several times while in this industry when I really wished I didn't know what I know. In at least a dual role (editor and CEO), I find myself privy to information that should not be publicly disclosed, but is important enough for the future and integrity of the industry, that morally, it needs to be at least shared - in principle. Even if only to let others know what to watch for, the signs and signals of self-destructive behavior, in some cases, especially if we really do care about building a better industry, we have to at least tell part of the story.

And with that ominous beginning, I'll start....

Those that have been part of back room (and some frank front room) discussions know that there are some very erratic purchasing behaviors out there. When mass doesn't add up to market sales, you know that commodity ingredients are being purchased to bulk up a branded ingredient purchase to either let the manufacturer use a trademark, leverage intellectual property or utlize proprietary science to substantiate a claim. In this more transparent enviironment, presumably this 'dusting' procedure is used to leverage an NDI submission, a proprietary health claim or in Canada, a Natural Health Products ingredient dossier on file with Health Canada for the purposes of obtaining and presumably retaining a Product License. This is behavior that many frustrated ingredient suppliers have been trying to change for years. Presumably, a more accountable environment, with enforced GMPs, would put pressure and accountability on this area, but recent rumor suggests otherwise.

These are challenging times. While the industry has done reasonably well over the past twelve months, espcially compared to other sectors, there has been brand switching and an uptake of private label, putting serious pressure on branded manufacturers. All have responded differently to the challenge and I must say, in some cases, admirably. It's the other cases that have me really worried.

I recently became aware of the fact that a decent-size branded manufacturer had changed its purchasing practices, relying more on non-branded ingredient suppliers. This company continues to purchase some branded ingredient, presumably, at the very least, to be able to reference and utilize the high level ingredient specifications, substantiation and perhaps even production processes included in documents submitted to the regulatory authorities. And because the company continues to purchase some materials from the branded guys, that company is held hostage for the rest of their busienss and so whistle blowing becomes self-destructive.

So while the regulatory authorities are just getting up to speed on normal enforcement, can we practically expect them to enforce at this level? Presumably a safety/risk issue has been introduced and one would think the practice is illegal if not at least misleading. I guess technically, through an inspection of documentation, these purchase orders would be found....or would they? Could this mass/balance issue be disguised? It certainly could in the absence of on-site enforcement. What happens in the event of a serious AER? Could this practice confound the investigation? And just how widespread is this practice?

I know that I am frequently asked to provide brand guidance - at both ingredient and finished brand manufacturer levels of the value chain. This recent information has changed my practices and reaffirmed my belief that something is indeed rotten. Unrtil we, as an industry, can change these behaviors, we'll have a hard time growing up and gaining some of the credibility we do deserve.