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Jennifer Grebow is editor-in-chief of Nutritional Outlook.
CDX is a repository wherein manufacturers can post and share additional product information directly with retailers.
The Council for Responsible Nutrition (CRN; Washington, DC) is initiating a pilot program for the Commercial Data Exchange (CDX) portion of the Supplement OWL registry. CDX is a repository wherein manufacturers can post and share additional product information directly with retailers-specifically, quality data, including third-party Good Manufacturing Practices (GMP) certifications, finished-product testing results, product-attribute information (e.g., gluten-free, GMO-free, allergen-free, or halal or kosher certifications), structure-function claim notifications, and more. The goal of CRN’s new pilot program is to spur manufacturer participation in CDX, the association says.
In April 2017, CRN launched the industry-led, self-regulatory Supplement OWL (Online Wellness Library), a product registry in which, free of charge, all manufacturers in the dietary supplements industry can list, for public viewing, an image of each of their dietary supplement product labels as well as searchable product information such as ingredient lists, serving size, claims or uses, and directions for use. The goal of the Supplement OWL is to provide, with a single repository of information, enhanced industry transparency so that consumers, regulators, and retailers can better determine which products currently exist in the dietary supplement market.
While this area of the Supplement OWL is free of charge and openly accessible, there is another component, CDX (formerly called “Tier 2”), for which supplement manufacturers can pay to post documentation related to the quality-assurance measures described above (lab results and certifications, etc.). Companies can then choose to share their information with retailers, who are able to review companies’ documentation within CDX free of charge-the idea being that retailers want to work with companies with proper testing and certifications only.
Like the Supplement OWL, the goal of CDX is to increase transparency and information accessibility for retailers, specifically, and to provide manufacturers with an easy, singular place to store and share their quality-control documentation with retailers. Duffy MacKay, ND, CRN’s senior vice president, scientific and regulatory affairs, tells Nutritional Outlook: “So if I’m working with Walmart, and Walmart says, ‘Hey, are you in CDX? Can you give me access?’ I can give them user access to my CDX documents, and then that Walmart person can log into the OWL and now they can see all these documents.”
Companies must pay $25 per product label to participate in CDX and must first register as OWL participants. While CDX has already been operational, MacKay says that participation is currently “a little light.” As such, he says, CRN’s new pilot program is meant to invigorate activity. The association will invite a select number of manufacturers to participate in CDX free of charge. MacKay says that once industry-leading manufacturers are using CDX, more manufacturers hopefully will, as well. “That’s what we’ve learned in this industry is that as soon as a few leader companies and forward-thinking companies do something, you see the others say, ‘Oh, yeah, this is a great idea,’ and they start embracing it,” he says.
“What CRN is committing to is a pilot program where we are actually going to invite a host of companies to participate in CDX,” he adds. “We’re going to pay the bill at CRN, and we’re going to have them put their information there. And then we’re going to work with retailers to really refine and make sure that the user interface is correct and that the type of information they’re looking for is there, and we’re going to continue to improve upon it.” For companies selected to participate in the pilot program, CRN says it will waive the CDX fee for the first 25 labels. Participation is open to CRN members on a “first come, first served” basis.
Already, CRN recruited retailers to share their views on what types of information they most want to see in CDX and tailored the framework accordingly. As a result, MacKay said, CRN winnowed down the types of documentation to five key areas-some of them described above-to streamline the information in CDX to ensure it is truly useful to retailers. MacKay says that CRN is flexible in terms of further refining CDX to retailers’ needs. “If, all of a sudden, retailers tell us that this is an important piece [of information] to add, we’d be willing to make changes based on the feedback during this pilot program,” he says. During the pilot program, CRN says it will encourage participating companies to provide feedback on their experience using CDX.
He also points out that CDX hopes to work hand in hand with other self-regulatory frameworks coming to market. One of them is the Global Retailer and Manufacturer Alliance (GRMA), a global nonprofit organization whose members include retailers, manufacturers, trade associations, and certification bodies, with the goal of developing consensus-based American National Standards for Good Manufacturing Practices in several industries. Another is the Supplement Safety and Compliance Initiative (SSCI), a quality-assurance benchmarking initiative led by the Natural Products Association (Washington, DC) as well as retailers such as GNC, Walmart, Vitamin Shoppe, and Whole Foods.
It’s possible CDX could serve as a place where companies store their documentation supporting these initiatives. MacKay says, “We’re trying to work with them to make sure that the documents they create to show that you’re in compliance with the benchmarks they’re creating would fit with showing them off in the OWL via CDX.”
The deadline to register for the CDX pilot program is December 31, 2018. The pilot program will conclude in April 2019, the date marking the Supplement OWL’s two-year anniversary. Visit www.crnusa.org/OWL-CDX to apply for the pilot program.