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We sent out a survey to a random group of customers (doctors and other wholsale accounts). The survey was one question:
Would you have any concerns if Blue Ice CLO vitamin A/D was not on the the label but rather we list a wide range of test data on a regular basis on our depending website?
We would list quinones, different types of A, different forms of D, K's, PCB's, metals, minerals, peroxide, and any other test we many conduct . The test results would not be tied to any specific lot or jar but more for discussion and intrigue.
The concern that facilitated the discussion is there are a wide range of test results on method and lab. In addition, there are thousands of nutrients within fclo including many minor forms of A/D that are not currently discussed.
The FDA views a dietary supplement like a drug and the FCLO is more like a food. Drugs have 'known' amounts of very specific ADDED nutrients (if one wants to call lab made molecules nutrients). Lab nutrients can be easily measured and reported.
After working with the product for 5 years my conclusion is that media medicine and FDA label requirements do not fit the fclo. It is like putting a square peg in a round hole. It is beyond vitamin A and D. It is not proper to tie fclo into a standard clo discussion nor can the product accurately be defined in these terms. We get question about A/D/EPA/DHA
and we do discuss openly and as a result sometimes people struggle to understand the concept that the fclo is not a drug and it is not as easy as it has exactly 842 iu's of vitamin D per ml and this will do this or that in your body.
******Give away Code WAPF*******
It took me 3 years to come to the conclusion that the product can not be defined in standard media medicine terms and there is no need to know these things other than discussion/intrigue as the product is what it is as it has been for thousands of years (prior to the industrialization of fish oils). Not knowing this or that does not change the product nor how one should use/consume the product.
What the survey revealed is about 75% of practitioners do not have an issue with not listing the A/D on the jar. I guess for the most part they know how it works and use it every day in their practice. Their patients do as prescribed. As a group they understand much more complete than myself. It took my hard headed attitude 3+ years to reach a conclusion as this group did in just a few short months of working with the product.
The general wholesale accounts there was more concern about the label vitamin A/D issue. Approx 70% had a concern if the A/D was not on the label.
My conclusion is that i need to spend more time teaching. We will have a new web site in short order that will have more information and i think be more user friendly. Plus i will travel to locations throughout the country over the next year speaking on the history of FCLO and testing.
Below are samples of comments from the survey. Drop me a note if you would like to post your opinion. I see all emails that make it through the web.
***"i think it will drive more traffic through the web site, and take the burden away from potential fda issues"
***I educate my patients and the difference between food and supplements. They will understand and it won't be an issue.
***I get so many questions on the label anyway that I think providing the test data on the website would be more accurate.
***Can you just include the weight of the vitamins and omega 3's without listing the %DV or just the %DV and not the weights like most food products do? My concern is the many people who do not have internet access. Living in the heart of an old order Amish community I am pretty sensitive to this, but I do understand your concerns in regard to the oils being a food as opposed to a supplement. Why can't the label be more like foods - Nutrition Facts not Supplement Facts?
I prefer as much info on the label as possible. I'm not sure what the reason would be for removing it, but if there was an important reason, I'd be fine with it.
***Another thing you should consider (and you should check with your legal counsel on this), by referring your customers to your website from the label, you are making your website an extension of your label, thereby potentially requiring your website to comply with FDA guidelines. Again, I'm not an attorney, but I've had this issue brought to my attention more than a few times.
***We love recommending your products because we know the customers will love them once they buy. Just wish they were more buyer friendly."
***Maybe on the label you can state how an food oil can differ in it's make-up from each batch and how the most current data is on the website as it is 'ever-changing'.
I have many customers taking these products with specific vitamin A dosing recommendations from their healthcare practitioner. We regularly receive complaints about the current labels. Customers find the information confusing because they are familiar with typical supplement labels.
***I just think that folks would really appreciate having the vit. A/D info. on the label. It would save me some time with all the educating I do on the product.
***Would rather see a general "range" on the label and refer clients to web site for more education and possibly more specific A/D measurements.
***I would love to schedule you to come out for a FCLO Symposium anytime after Christmas. Let's talk when you have time. If you give me some dates, I will line up the location. Ideally I would network through our WAPF chapter as well as local markets and publications and other practitioners.
***I think that removing vitamin A/D from the label will further confuse a generally confused public and may hurt sales as people will not SEE the benefit on the label to justify the higher cost of this product over competitors.
I think this would be just fine considering your target market Dave. Probably be much easier for all concerned.
***Concerning the European (Dutch) legislation we do need to fulfil the labelling complete with the contents of Vitamin A/D and % DV. Each and every content the is mentioned on a label needs to be written down on the label in mg, ug per survey. This is the information we need to put on the label of each product.
***"I like the idea of hosting you for a presentation in Dayton ,Ohio on Monday,February 21st or Monday, January 17th to explain all of this. Would you be able come on that day?
***"I have often referred to the supplement facts on the label and find it very convenient.
***Test data on the website would be nice too, in addition to the label."
"It seems my customers want to know not only what is in a product but how much of it.This can be frustrating but it is, nevertheless, true.
***There are those who will check out the info on the website and those that will not.
Here in WV, there are people who still do not have computers nor do they want them. I kind of understand that sometimes : ) So I think many would lose out on knowing the facts.
***I do tell them all I know about the only true cod liver oil there is, the fermented kind. They buy it because they believe me but it would be nice to have more information to hand out.
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