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How Are Supplements Regulated?


supplement powder splashed on white back drop, with scoop sitting within it

Supplements are commonly used in the equine industry, with more than 80% of equine caretakers reporting using at least one type of supplement (Murray et al, 2015), but the average horse person may not be familiar with how the products they use are regulated.


Equine supplement regulation varies based on location. In Canada, equine supplements are regulated through Health Canada, however, involvement in regulatory programs was voluntary up until 2017. Currently, any company manufacturing, importing, distributing or selling supplements has to enlist in the Veterinary Health Products program under Health Canada, with the following rules:


  • Must follow Good Manufacturing Practices to ensure quality, while reducing contamination risk.

  • Must contain active ingredients from an approved ingredient list (See Health Canada’s List C: VHP), which includes ingredients that are Generally Recognized As Safe (GRAS).

  • Must follow FDA label standards, have “Veterinary Health Product” and include any mandatory ingredient statements as dictated from List C. Exm: “Not for use in pregnant or lactating animals”.

  • Must notify Health Canada 30 days prior to the supplement being sold/changed/imported.

  • Must report any adverse reactions.


In the USA, animal supplements are regulated under the Food, Drug, and Cosmetic Act, by the Center for Veterinary Medicine (CVM) branch. Supplements must contain ingredients that have been previously approved for use in animal feed (minerals/vitamins/herbs/etc), but premarket approval and manufacturing standards are not required. The CVM has the following criteria:

  • There is a known reason for each ingredient

  • Label states that the product is only for supplementation, not the daily ration

  • Product contains meaningful, but not excessive, amounts of the nutrients they claim to contain

  • Labeling shouldn’t contain disease prevention or therapeutic claims

  • No misleading/false labeling

  • Product neither over-potent, under-potent, or at risk to be a hazard

While the CVM can take action against products that violate these criteria, products are not monitored in a standardized manner.


That said, the National Animal Supplement Council (NASC) is a voluntary program that supplement companies can join should they meet with the standards. Approved brands that meet their quality standards are listed on the NASC website (www.animalsupplements.org), which can provide some peace of mind for USA-consumers since the current mandatory regulation does not cover manufacturing quality standards.


As they are not ‘drugs’, supplements cannot claim to treat, cure or prevent ailments (only ‘support’), so efficacy is not required to be guaranteed by regulatory bodies. Efficacy testing is left to the manufacturer, and while many companies base their products ON research, they do not do research ON their product. Instead, supplements are formulated based on existing literature (and may include “backed by science” in their marketing). This is a great start, however, does not always guarantee that the product itself will have the intended effect for numerous reasons:


  • Research done in other animals does not always yield the same results when tested in horses.

  • Current regulations also do not guarantee that scientifically proven ingredients ( ‘backed by science’) are being provided at the therapeutic dose, rather than acting as a “fairy dust ingredient” to give the impression of a benefit.

    • Even more, evaluation of ingredient levels in several types of supplements have reported lower ingredient levels than guaranteed on the label (Finno, 2020).

  • While ingredients found in the product may be safe & effective on their own, different chemicals within ingredients can have complex relationships with each other, and different chemical forms of the same ingredient have different absorption rates. You could formulate a supplement of theoretically superhero ingredients, but how these ingredients work together (both in storage & in the body) can impact efficacy & safety.


Current regulations may improve quality and reduce contamination risk, they do not guarantee that the product will have the intended effect. As such, the consumer must sort through smart advertising, a plethora of products on the market, and ingredient lists when choosing an effective supplement. Applying a critical lens and looking for companies who provide a guaranteed analysis and ingredient list are great strategies to start with!


It is important to keep in mind that the ideal use of a supplement is to complete or enhance the diet by topping up nutrient gaps between the animal’s current diet and the requirement (or therapeutic level), so supplement suitability also depends on your horse’s diet! It is always a good idea to work with your veterinarian and a nutritionist to identify your horse’s dietary requirements, then develop an unbiased plan on how to supplement to meet them, and which product to meet them with!


 

REFERENCES


Murray, JMD., Bloxham, C., Kulifay, J., Stevenson, A., Roberts, J. 2015. Equine Nutrition: A Survey of Perceptions and Practices of Horse Owners Undertaking a Massive Open Online Course in Equine Nutrition. Journal of Equine Veterinary Science 3596): 510-517. DOI: https://doi.org/10.1016/j.jevs.2015.02.005



Health Canada. 2023. List C: Veterinary Health Products. Government of Canada. Accessed online from:



Finno, CJ. 2020. Veterinary Pet Supplements and Nutraceuticals. Nutr Today 55(2): 97-101. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7802882/





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