Regulatory & Product Strategy / Service

Dietary Supplements, Consumer Health & Non-Prescription

Translating global product concepts into U.S.-appropriate regulatory, scientific, quality, claims, and commercial strategies.

Dietary supplements and consumer health regulatory advisory

The Work

A product that is a well-understood supplement, functional food, or consumer health product in one country can hit a very different regulatory frame the moment it lands in the United States. DSHEA defines what a dietary supplement is, what it can claim, and where the line is between a structure/function claim and a drug claim. Quality expectations under 21 CFR Part 111 sit above what many global manufacturers carry as standard. Retailers add their own documentation, testing, and label-language expectations on top of the federal frame. RGM helps companies translate the original product concept into something that holds up in U.S. regulation, U.S. retail, and U.S. consumer scrutiny.

The work draws on decades of operating experience leading regulatory, scientific, quality, and commercial strategy across dietary supplements, OTC drugs, and consumer healthcare in the U.S. and globally. The goal is a U.S. version of the product that is regulatorily defensible, commercially credible, and operationally feasible — not a translation that collapses on first scrutiny.

What's typically included

  • U.S. regulatory framing — whether the product belongs in the dietary supplement frame under DSHEA, in the OTC drug frame, in the conventional food/functional food frame, or in a combination posture, and the implications of each.
  • Claims feasibility — structured review of intended claims against the structure/function vs. drug-claim line, and the evidence that would be needed to defend them.
  • Quality & specification expectations — senior read on what 21 CFR Part 111 expects of the product, the formulation, the contract manufacturer, and the brand owner.
  • Scientific & evidence strategy — pragmatic recommendations on the evidence the product actually needs to support its U.S. claims and retailer requirements.
  • Commercial positioning — how the product can credibly hold its place in U.S. retail and channel, including label, claims, and category framing.

When this is the right conversation

Global brands typically engage RGM here when a product that performs in another market is being readied for the U.S.; U.S. supplement companies when a new product concept needs an early read on whether it sits inside DSHEA or crosses into drug-claim territory; and consumer health innovators when claims, evidence, and quality need to be reconciled before a launch is committed.

Output you can use

A documented view of where the product fits in the U.S. regulatory landscape, what it can and cannot claim, what evidence and quality posture it needs to defend that position, and what changes (formulation, label, claims, manufacturing posture) are required to make the U.S. version viable. Written so it can drive a launch decision at the leadership table.

Bringing a supplement or consumer health product into the U.S.?

Tell us about the product, the claims, and where it sits today.

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