Registration—The registration fee for each product label or change in product formula is based on the number of components/ingredients for each label registered and must be paid at time of label registration as follows:

There is a $10 processing fee per Form A submitted. The registration fee for additional sizes of a product is $2 per label when labels of additional sizes are submitted with original label. Submitting additional sizes at a later date will result in registering the product as a new registration.

Annual Maintenance Fee—TruLabel members are invoiced an annual maintenance fee of $25 per company with an additional $2 per currently registered label for the first 250 labels and $1 per label over 250, which have not had revisions to product contents or label claims.

Random Testing—Please note, testing fees are only paid if the TruLabel member’s product is selected and tested under a specific TruLabel test. There is a maximum potential annual laboratory cost for any company entered in the program. The annual testing fees for a company are capped based on the number of labels enrolled, as follows:

TruLabel consists of a computerized database containing information on the label contents of products entered in the program. Products are periodically selected for laboratory analysis to confirm the label. Selection may occur through several mechanisms including:

• Selection of categories (such as vitamin C single ingredient) identified by ComPLI.
• Selection of best sellers, random selection of products.
• Selection based on complaints.

The TruLabel logo and reference to the TruLabel program may not be used in any marketing material or by manufacturer representatives or others involved in marketing, sales or otherwise.

NPA does not review labels for compliance with federal labeling laws. The names, UPC numbers, and ingredients (including processing aids, excipients and binders) of all products are entered into a computerized database. Membership in TruLabel does not necessarily imply compliance with federal labeling laws. It is the supplier’s responsibility to ensure their labels and label claims are accurate and in compliance with all applicable regulations.

The TruLabel program is an internal oversight program, providing useful information about dietary supplement products as well as dietary ingredients in the marketplace. This information has been very valuable over the years, especially when there is a potential concern regarding a product, an ingredient, label claim, etc. In these situations, NPA can mine information from the database to address the issue and identify companies that may be impacted and notify them if they have a product and/or ingredient under scrutiny by the FDA or for which there are emerging issues or concerns. This background information can provide companies with resources to prepare for any changes that need to be made or to respond to questions/concerns from consumers.

Additionally, results from the TruLabel Random Testing have been published in the press other than NPA NOW, gaining attention for those companies whose product successfully passed a random test.

As the first industry quality assurance certification program, the TruLabel program has the respect and support of our industry champions on Capitol Hill and continues to give NPA credibility when addressing various issues.

NPA member suppliers whose brands were not included in an original TruLabel test may request testing of their product through the Ad Hoc TruLabel Testing Program. The product to be tested must fit the criteria of the original test. This testing will be carried out following the current TruLabel program protocol, utilizing the same lab, and using the same analytical method utilized for the original TruLabel test. There are several differences however, with the Ad Hoc program requiring suppliers to fill out a request for Ad Hoc testing and submit retail locations where their product can be obtained, all products submitted for Ad Hoc testing must be registered in the TruLabel program; and fees for the Ad Hoc testing must be paid in advance of testing.

Ad Hoc test results are proprietary to the member supplier. However, if a product “Passes,” it will be added to the NPA website listing. The Ad Hoc Testing Program is available for products for which a TruLabel test has been conducted or is already underway.

To register your products with the TruLabel program you will need to use Form A and Form B in the TruLabel Enrollment Packet [pdf]. Use Form B to register each individual product and attach label to form and check appropriate boxes on the form for registration. Form A is a summary cover letter of your registration that you are submitting.

If there is a change to the product label, you will need to notify NPA with the change by using Form B and check appropriate boxes on the form. A product formulation change will require you to re-register the product. Additional sizes of an already registered product will require registration as a new product and charged either $5 for 1–10 ingredients or $10 for 11+ ingredients.