Session Preview: Building Credible Science-Backed Brands in Active Nutrition

In this interview, Diana Morgan, MS, CISSN, chief catalyst and founder of Pink Catalyst Consulting, previews her upcoming session at Nutritional Outlook's Outlook on Active Nutrition conference, focused on influencer-driven brands outpacing legacy companies in consumer engagement and speed to market.

She explains that regulatory considerations are often treated as an afterthought by influencer-led brands, which frequently develop a formulation first and only later ask how to substantiate the claims they want to make, rather than building claims strategy into product development from the start. She notes this applies not just to structure-function and health claims, but to sustainability, recyclable packaging, and non-GMO or vegan claims as well, all of which require substantiation.

Morgan also pushes back on the common misconception that dietary supplements are a largely unregulated industry, arguing that the presence of bad actors in any category, including pharma and cosmetics, shouldn't overshadow the many brands operating with rigorous testing and compliance standards. For smaller brands without large research and development budgets, she recommends starting with trademarked, branded ingredients backed by existing company-funded research as a first step, working toward finished-product studies over time rather than relying solely on borrowed ingredient-level science.

The conversation also covers how major retailers, including Amazon, Target, and Walmart, are tightening compliance expectations, sometimes requesting claims substantiation directly, and a notable regulatory PSA: Morgan references an FDA warning advising supplement brands not to share their FDA food facility identification numbers with retailers like TikTok Shop, citing risk of misuse by bad actors. She closes by previewing other conference sessions she's especially anticipating, on GLP-1 medications and peptides, noting their overlap given ongoing concerns about muscle loss associated with GLP-1 use.

Learn more and register for the conference here—a transcript of their conversation can also be found below.

Nicholas Saraceno: Welcome to another installment of the Nutritional Outlook video series. I am Nico Saraceno, senior editor of Nutritional Outlook magazine, and today I'm joined by a very special guest. She is Diana Morgan, the chief catalyst and founder of Pink Catalyst Consulting. Diana, thank you so much for coming into the studio and for being here today.

Diana Morgan: Absolutely. Thank you so much for having me in my home state of New Jersey. I got to drive down the turnpike where you famously stare out the window, looking over the turnpike. So yes, luckily, no traffic today. Weather was cooperating since we've had bad storms, but I'm so excited to be here. The studio is awesome. I love everything and excited to chat with you.

Saraceno: You were able to experience the wonderful scenic views that I've been referring to coming down to exit 8A here. Fun stuff. I know we want to get into a lot today. One of them is, of course, our upcoming Outlook on Active Nutrition conference. It's going to be here before we know it. It's in September. So we have a lot of great sessions in that conference, including yours. You're actually talking about influencer-driven brands outpacing legacy companies in consumer engagement and speed to market. That's all-encompassing right there.

I'm curious, given your regulatory and your background with product development, where have you seen most often that kind of speed creating real risk versus like just growing pains and things like that, that fast moving brands might go through? Could you maybe get into that a little bit?

Morgan: With influencer-led brands, it's very much about the face of the influencer getting consumers to use their product. And a lot of times I've seen, especially in regulatory, that regulatory is the afterthought for a lot of these formulations. And unfortunately, we oftentimes have to work backwards. What I've seen is brands come out with formulations and then say, oh, well, these are the claims we want to make. And then I'm looking at it from a regulatory and scientific perspective, and how are you supposed to make these claims based off this formulation?

It seems like because some branches really just want to get to market as quick as possible, they sometimes forget that regulatory needs to validate the science. We need to validate the claims from an FDA and FTC perspective. But then that's not only the structure function or like the health claims, you have claims like recyclable packaging. That is a claim that needs to be substantiated. You have the sustainability claims. You have claims like non-GMO, vegan, vegetarian, all those other fun claims that again, just because they're not in the realm of a structure-function claim, they still need to be substantiated.

I always tell every single brand, even if you think you don't need regulatory yet, just get them involved. And what I try to do with my brands is not be the naysayer or the no regulatory person. I say get as expansive as you want to get, and then I will give you guidance on how to get where you're going. So we don't have to do it in the 11th hour.

Saraceno: I think it's interesting because a lot of people that might not know this whole natural products nutraceuticals industry, they're like, wait a minute, isn't this 1 of the least regulated industries? I feel like that's a very common misconception. A lot of thought leaders have been talking about that, especially on LinkedIn, so I'm happy that you're helping provide clarity to that because that's like a big misconception.

Morgan: Yeah, and I agree with you. I mean, even my own friends and family say the same thing. And it's definitely a myth because if the supplement industry wasn't as regulated as it is, I wouldn't have had a job for over 20 years. It's very important that from an industry perspective that we also educate consumers and put out the positive media articles on how the supplement industry is regulated.

I say this all the time—there's bad players in every category, whether it's pharma or OTC drugs or cosmetics or dietary supplements. The bad players are always going to be there. But then you have the brands that have had legacy of decades making quality products that are out there testing and showing their results, and doing the right thing. We just need to have more brands like that and really highlight those brands.

Saraceno: I agree, and I know that in your actual session, you're going to be diving into this shift from personality-led marketing to kind of like you said, claims-based, evidence-backed brand building that all these brands are looking for. I'm curious for, say like a newer, smaller brand in the industry that might not have that big R&D budget that these heavy hitters have, what would you say like is a realistic step 1, towards clinical validation? What does that look like? Where do they even start on something like that?

Morgan: What I would recommend is that brands start with an ingredient that has the science behind it already, and that typically comes with a branded ingredient. A trademarked raw material. The only reason I say to use a trademarked raw material is because those companies are investing in their own science. You have a raw material that might not be trademarked. They are using borrowed science, and while it can be supporting evidence, really having the data on your specific product. That would be step 1.

Obviously, consumers, FTC, and FDA want studies on your finished product, on the combination of all the different ingredients together and how they can work synergistically or in the opposite way, how it can diminish some of the ingredients when they work together. Step 1 would be to start with raw material suppliers that have branded ingredients, that have done studies on their own products, and then try to get to the next level of doing a study on your finished product.

Saraceno: You mentioned that, or are going to mention how retailers and platforms are starting to prioritize this whole idea of data credibility. Brand momentum is also key. Would you say that's apparent when it comes to the buying or the listing decisions, and what are retailers asking of brands? Can you maybe get into that evolution?

Morgan: Yeah, it's very different than it was 5 years ago even. You see a lot of brands that are taking or retailers that are taking compliance very seriously. It might be because FDA has come after the retailer. The retailers really do have a responsibility to know what they're selling. So we have seen some of the larger retailers, like the Amazons of the world, the Targets, the Walmarts, which also make their own private label products too. They are getting into the space with their private label products. A lot these big retailers are, are part of industry trade associations. They have full regulatory teams. Third-party testing, that's very important, you've seen it with Amazon. Their standards are very, very intense.

Getting third-party testing and showing the testing results to make sure that what's in the product is on the label, nothing more, nothing less. Some retailers, I've been even seeing that they want substantiation for some claims. So for example, I think it's Target. They go through their pharmacy department, and the pharmacy department is very much in that pharma OTC mindset. Even sometimes substantiation for their claims, they might want to see studies. I think this is also very important that the brand owner speaks with their legal or regulatory team before sending anything to these retailers, because sometimes, the retailers can be asking for things that are proprietary and that are for internal use only.

FDA had actually posted something, I think it was on July 22, about TikTok. There's a lot of brands selling on TikTok Shop, and TikTok has been asking some brand owners for their FDA food facility identification number. FDA said, please do not send this identification number out to retailers, especially TikTok. It's proprietary. Unscrupulous players can be using another brand's food facility identification number for their own brand. That's something I would highly recommend not sending out and just being very mindful of the information that you're sending to retailers if it's confidential and you do have a confidentiality agreement in place with these retailers.

Saraceno: Wow, that's scary. I feel like that can open up a whole other can of worms. It's like making sure you're staffing properly too. I feel like that's a whole other issue. Thank you for adding that as a PSA too, because I feel like some industry members might not be too aware of what's going on there.

Morgan: Definitely.

Saraceno: I don't know if you've looked at the agenda that we built out thus far, but are there any other sessions maybe that you're looking forward to that you're intrigued by and that you might recommend for the rest of the attendees to check out potentially?

Morgan: I'm actually excited for the entire conference because this area is really my sweet spot. I love being active and all the nutritional aspects of what the female athlete needs to think about. The 2 sessions that I think really will go hand-in-hand, I think it's in the morning and then as a closing session, are the GLP-1 session with Doug Kalman and then Ben Kane speaking about peptides. They go hand-in-hand because GLP-1s are peptides. There are 2 different aspects of it because almost everybody and their mother is on a GLP-1 for weight loss, and it's going to be very dangerous for muscle retention. You have all these people that just want to get skinny, but when they come off of them, you know, they can't stay on a GLP-1 forever. The amount of muscle wasting that's happening is very dangerous, especially as you get older because you need muscle to be able to walk and not have falls.