Lacsa Radar

FDA Turns Up Scrutiny on NDI Notifications

Brands launching novel ingredients should expect more questions, not fewer, from FDA reviewers this year.

The New Dietary Ingredient notification pathway has always been underused, but FDA has been signaling closer attention to safety substantiation for ingredients that don't have a long history of use. For brand owners, this means the days of quietly launching a novel botanical extract or new delivery form of an existing ingredient without documentation are numbered. If your formulation includes anything outside the standard, well-established ingredient list, you need a paper trail: sourcing history, any prior safety data, and a rationale for why the ingredient qualifies as dietary rather than a drug. Waiting until a product is on shelf to assemble this file is the wrong order of operations. A contract manufacturer that has already been through NDI conversations with regulators can save months of back-and-forth. The practical takeaway is simple: before you commit to a novel active for a fall or year-end launch, get your documentation reviewed now, not after formulation is locked.

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