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The American Herbal Products Association (AHPA) has adopted a new trade recommendation for Hoodia gordonii raw materials and finished products containing the increasingly popular herbal material from Hoodia gordonii, a succulent plant from the arid lands of western South Africa and Namibia.1
The new AHPA policy establishes basic requirements for proper identification of Hoodia gordonii that are consistent with federal labeling regulations [21 CFR 101.4(h)]. These regulations state that the U.S. Food and Drug Administration recognizes the AHPA recommended standardized common name for herbs sold in commerce in the United States. AHPA has decided that the “standardized common name” (SCN) for this herb is “Hoodia gordonii” - not “hoodia” - and the AHPA SCN is the name that must appear on labels. All herbal product labels should also accurately identify the plant part used, usually consisting of “aerial parts” or “above-ground parts.” This is also consistent with FDA regulations.
The AHPA recommendation also deals with the labeling of extracts made from H. gordonii. Any use of the long-established herbal extract ratio terminology, stated as a ratio of 2 numbers (e.g., “20:1”), must be consistent with established practice and with AHPA’s Guidance for Retail Labeling of Dietary Supplements Containing Soft or Powdered Extracts 2 This requires that the first number in any such ratio must represent the amount of dehydrated starting plant material and the second number must represent the amount of a finished extract; and further, that such ratios should not be used on any product that is not, in fact, an extract.
“There has been some marketplace confusion about how some Hoodia gordonii products are labeled,” said AHPA President Michael McGuffin in the AHPA release. “At the same time, none of the elements of this trade recommendation should be surprising or problematic for most companies.”
The question may be raised as to why AHPA chose “Hoodia gordonii” as the SCN instead of the more convenient “hoodia” which has become the widely used common name in commerce in the U.S. during the past 3 years that this herb has achieved such strong popularity as an ingredient in dietary supplements marketed for weight loss. The federal law governing labeling of dietary supplements (cited above) states that the Latin binomial of a plant sold in U.S. commerce, unless it already has an SCN published in AHPA’s Herbs of Commerce, 2d ed. 3, requires the Latin Binomial.* Because Hoodia gordonii is not listed in Herbs of Commerce, federal regulations require the full binomial be used. [K. Robin (AHPA). Personal communication (e-mail), Mar. 1, 2006.]
AHPA also noted that that Hoodia gordonii has occasionally been erroneously referred to in the media and company websites as a “cactus.” Hoodia is not a cactus; it is a member of the buttefly weed family (Asclepiadaceae). AHPA is concerned that the erroneous description or naming of hoodia as a cactus may have lead to some confusion with an actual cactus that is in commerce: the prickly pear cactus (Opuntia ficus-indica).
AHPA trade recommendations constitute an amendment to the association’s AHPA Code of Ethics and Business Conduct. Therefore, the new trade recommendation released by AHPA constitutes an amendment to the Code and should be considered as such by all AHPA members. AHPA’s Code of Ethics is posted on the AHPA website at http://www.ahpa.org/06_0100_AHPA_CodeOfEthics.pdf.
AHPA has been active in creating numerous self-regulatory initiatives to help regulate practices and ethics in the U.S. herb trade for more than 20 years. For more information on AHPA’s self-regulatory policies, see articles in HerbalGram. 4-7
* “(2) The Latin binomial name of the plant, in parentheses, except that this name is not required when it is available in the reference entitled: Herbs of Commerce for the common or usual name listed on the label, and, when required, the Latin binomial name [sic] may be listed before the part of the plant.” [21CFR101.4(h)]
References
1. American Herbal Products Association. AHPA Adopts Labeling Standards for Hoodia gordonii [press release]. Silver Spring, MD: American Herbal Products Assn., Feb. 22, 2006.
2. American Herbal Products Association. AHPA Guidance Policies: Guidance for Retail Labeling of Dietary Supplements Containing Soft or Powdered Extracts. Sliver Spring, MD: American Herbal Products Assn. Feb. 22, 2006. Available at: http://www.ahpa.org/guidelines.htm.
3. McGuffin M, Kartesz JT, Leung AY, Tucker AO. American Herbal Products Association's Herbs of Commerce, 2nd ed. Silver Spring, MD: American Herbal Products Association, 2000
4. Blumenthal M. Self-Regulation by the Herb Industry. HerbalGram. 2006;69:4-5.
5. Blumenthal M. AHPA Adopts New and Revised Trade Recommendations for Herb Industry Self-Regulation. HerbalGram. 2006;69:56-58.
6. Blumenthal M. Herb Industry Self-Regulation Initiative on Common Names for Herbal Ingredients Becomes Federal Law in January. HerbalGram. 2006;69:60-61.
7. McGuffin M. Self Regulatory Initiatives by the Herbal Industry. HerbalGram. 2000;48:42
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