Why CRN Built a Superhero Around the Dietary Supplement Listing Act

In this interview with Nutritional Outlook, Steve Mister, president and CEO of the Council for Responsible Nutrition (CRN), discusses the origins of Sergeant Searchlight, a comic-style advocacy campaign built to support the Dietary Supplement Listing Act. Mister explains that the character emerged after 6 years of policy work on a mandatory registry, including a dozen published articles and a journal piece he authored roughly 4 years ago outlining how a registry would give the FDA greater visibility into the supplement marketplace.

With 2 bills now introduced in Congress, one in the House and one in the Senate, Mister says the campaign was designed to cut through opposition arguments—that a registry would be unworkable or unnecessarily burdensome—with a more approachable, lighthearted tone aimed primarily at congressional staff ahead of CRN's recent Day on the Hill.

Mister also addresses why a mandatory registry is needed despite the existence of voluntary databases already used by many manufacturers. He contrasts CRN's own Supplement OWL, which is controlled by brand owners, with the Dietary Supplement Label Database run by the National Institutes of Health's Office of Dietary Supplements, which he says is populated in part by contractor web-scraping and does not reliably remove discontinued products.

Under a mandatory system, Mister explains, brand owners would be responsible for submitting and updating their own listings, including removing products no longer on the market. He frames the registry less as a burden than as a baseline credibility marker, arguing that after 21 years at CRN, companies have consistently asked for a reliable way to distinguish compliant manufacturers from bad actors, and that willingness to register with FDA is, in his words, close to the minimum requirement for operating in the industry.

A transcript of their conversation can be found below.

Nicholas Saraceno: Ladies and gentlemen, welcome to another video series here on Nutritional Outlook. Of course, I am Nico Saraceno. I am the senior editor of Nutritional Outlook magazine. And joining me today is a very special guest. He is Steve Mister, president and CEO of the Council for Responsible Nutrition, also known for short as CRN.Steve, first of all, thanks so much for taking the time to hop on today. I really do appreciate it.

Steve Mister: Sure. Thanks for having me.

Saraceno: So we have a lot to get to today. I think everyone in the industry who's been on LinkedIn, who's been on X, who's connected to the “interwebs” and in some way, shape, or form has noticed this gentleman known as Sergeant Searchlight, which it's become a very effective way for explaining the Dietary Supplement Listing Act. It's almost like a comic book per se. There's storytelling, and the word on the street is that there was a superhero cape that was mailed in by one of your board members, which I thought was hilarious and great at the same time.

So I'm curious, Steve, what made you confident that like such a campaign that's built around humor and character, which I think is a positive thing, what made you so confident that that could move such a serious policy conversation forward in the ways that arguably conventional advocacy hadn't? What gave you that that idea for it, and what was your mindset there?

Mister: That’s a great question, Nick. We've been talking about a mandatory registry now for about 6 years, and we've been making some progress. We've got legislation introduced in Congress this term. We actually have 2 bills, one in the House and one in the Senate, so now it is a bicameral effort. We've got a lot of really good policy arguments. And when we started this campaign, we really focused on making sure that we had the policy side all buttoned up. We published at least a dozen different articles on various aspects of the industry. I authored a journal piece that went in depth about 4 years ago, as to why the registry was needed and how it would solve some very specific problems in the industry about allowing FDA to have more visibility into the dietary supplement marketplace, giving consumers insights into the products, giving retailers the ability to make better decisions about what products they put on their shelf or on their websites.

We really made a lot of progress on that side of things, but we realized that the arguments were almost getting a little wonky. We were so tied into the policy stuff that we wanted to be sure that we also stepped back and, and also kind of took a little bit of a lighthearted approach at the opposition that was making straw man arguments that the registry wouldn't work, that FDA wouldn't use it, that it was too burdensome for the industry. We sat down as a CRN staff team and said, how do we kind of break through against that kind of noise?

That led to the creation of Sergeant Searchlight. We thought, we can still have all of the really strong policy arguments, but we can also have some fun and let him kind of poke holes in the other side. He e was born this spring, as part of a lead up to our Day on the Hill that we had last week, where we brought a lot of our member company executives here on Capitol Hill. The primary target for Sergeant Searchlight has always been Congress and congressional staff. The larger audience of the industry has just been sort of, you know, to sort of gin up a little bit of excitement around that.

Saraceno: That's fantastic. I've noticed that the main premise behind Sergeant Searchlight is you can't regulate what you can't see. For the finished product manufacturers who are already participating in the in the voluntary registries like the Supplement OWL and things of that nature, what would you say is the main practical case for making these product listings mandatory rather than relying on industry self-regulation?

Mister: Well, as you say, the there are some databases out there now. CRN has the Supplement Owl, which is a voluntary database that is controlled by the manufacturers. They get to look at what is put in the registry for their product. There is also another database that's run by the Office of Dietary Supplements at NIH called the Dietary Supplement Label Database. That one is completely controlled by NIH and its contractor, so companies don't have any control over what the information is. They can submit the information, but in many cases, NIH's contractor is out there scraping the internet looking for products.

They may be grabbing labels that the company doesn't even know that they have found and put that in the database. The database never purges labels, so it has products in there that may have been removed from the market 10 years ago and the label is still there. So those are some of the problems with having a voluntary database and having one that is not controlled by industry. This registry, all of the information that would go into the registry would have to be submitted by the brand owner.

They would have control over what goes in. They would have the responsibility once a product has been discontinued and it's no longer on the market for taking it off. That’s the importance of having a mandatory registry. But I think the most important thing—and maybe I've buried the lead on this—is I've been at CRN now 21 years, and since I got here, companies have been saying we need ways to separate good actors from bad actors. Even if they're not perfect, we need ways to let consumers, retailers, other stakeholders, know who is trying to play by the rules.

The mandatory registry is 1 more way to do that. Because if a company is not willing to put its label up on a public facing database where FDA could find that company and then have review of its label, do inspections of the facilities, if they're not willing to do that, then, you know, I think that's sort of like, the lowest price of admission to get in the industry is to be able to say, I'm going to let FDA know I'm there, and I'm going to let retailers and consumers see my full label. So that really has been driving why we need a mandatory registry, as opposed to these voluntary programs.