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UNPA: Navigating Tariffs, GRAS, and State Actions | State of the Supplement Industry

The ripple effects of tariffs and trade policies will continue to reverberate into 2026.

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By: Loren Israelsen

Founder and President of the United Natural Products Alliance

Photo: weerasak | AdobeStock

As part of Nutraceuticals World’s 2026 State of the Industry review, Loren Israelsen, Founder and President of the United Natural Products Alliance (UNPA), discusses how tariffs, supply chain volatility, ingredient safety, and evolving state and federal regulations are among the key issues to watch.


The dietary supplement industry has managed tariff and supply chain issues as best we can based on what we know. Things are extremely fluid. That’s one of the problems we see. Changing tariff rates can happen overnight, for unexpected reasons, and with important countries: Brazil, India, and obviously China being the major one. Supply chains will try to soak up as much of the tariff hit as possible by distributing it throughout the system. The problem likely to emerge in Q1 is that, once that capacity is reached, the tariffs begin to flow more directly to the consumer.

In the case of India, based on the type of market it is, with hundreds of thousands of small farmers, they will take a disproportionate hit. I think we’re going to see shortages and much more expensive product coming out of India in Q1.

Going forward, we need to continue to look for other sourcing. That’s possible for some ingredients, but then we reach critical nutrients produced exclusively in China, such as vitamin D and folic acid. In those cases, we’re at the mercy of ongoing negotiations between the U.S. and China.

In my opinion, the U.S. government needs reserves of critical nutrients in case they are needed. As we’ve seen with rare earth minerals, China can put an export block on essential materials. Nutrients fall into that same category of critical materials needed to support infrastructure and public health.

GRAS

The majority of ingredient safety assessments have been done via GRAS without notice to FDA. Moving forward, companies will need to conduct GRAS assessments with the understanding that FDA will review filings. I would expect this will improve the overall quality of submissions, which I think is a good thing.

“In my opinion, the U.S. government needs reserves of critical nutrients in case they are needed. As we’ve seen with rare earth minerals, China can put an export block on essential materials. Nutrients fall into that same category of critical materials needed to support infrastructure and public health.”

ODIs and NDIs

I’m a big advocate for a much-expanded old dietary ingredient (ODI) list. The current list is very inadequate. It was built using only what we knew we were selling. For example, there are no prebiotics and no mushrooms on the ODI list. We believe we could double, even triple, the list with valuable and important additions. Cara Welch (Director of FDA’s Office of Dietary Supplement Programs) has noted that FDA uses the ODI list frequently, and they would very much like an improved version. We’re committed to it.

MAHA Expectations

Initially, my expectations were higher, based on statements made by Robert F. Kennedy, Jr. himself. Then we saw appointments of senior staff around him: FDA Commissioner Marty Makary, MD, is very supportive of many industry principles; Dr. Oz to the Centers for Medicare & Medicaid Services, and Jay Bhattacharya as Director of NIH. These are all people sympathetic to our industry. I thought, surely, there’s opportunity to advance important issues.

What has become apparent is that the movement itself, the MAHA Moms — what they want comes first. Their priorities include removing colors and dyes from foods, eliminating glyphosate from agriculture and our foods. They want results quickly.

State Actions

FDA has always told the states to stand down on food legislation, emphasizing federal preemption and the need for a unified national system. I agree with that. But RFK Jr. encouraged the states to pass legislation. It was a measure taken with the objective to deliver actionable wins on a consistent basis. FDA couldn’t get it done. Congress wasn’t going to get there. So if your objective is go fast and get some wins, have the states jump into it. And they did. That makes it challenging for companies navigating these changes. What happens on the back end, how food regulation and labeling can be reunified, will be a hard question. We have some interesting challenges coming down the road.

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