The dietary supplement industry is under a massive, well-organized attack, and this time, it’s not just coming from heavy-handed Senate bills. It comes from a Harvard organization named STRIPED, who’s using a unique attack vector: adolescent eating disorders.
The industry needs to take note, because this group is well-funded and they are seizing power over numerous regulatory affairs, removing consumer access to nutritional supplements in the process. The industry hasn’t seen anything quite like this, and frankly, it’s grossly unprepared for this level of warfare.
Eating disorders (EDs) are on the rise.
According to a 2019 research review, the prevalence of eating disorders more than doubled from 3.5% in the 2000-2006 period, to 7.8% in the 2008-2013 period.[1] Diagnosis rates within the United States are even higher than the global average. An estimated 9% of the American population will have an ED in their lifetimes.[2]
The most recent data isn’t any more encouraging – another systematic research review, published in 2023, found that hospitalizations for EDs rose by a staggering 48% from November 2019 to October 2021.[3] Unsurprisingly, this explosion in ED-related emergencies coincided with the severe intensification of ED-related symptoms, including depression and anxiety.[3]
We can all agree that eating disorders are an enormous public health burden, and absolutely tragic. These conditions have devastating consequences, not only for ED patients, but also for their friends, family, and acquaintances.
A grave situation
Take anorexia nervosa for example. The chronic malnutrition typical of anorexia often causes cardiovascular issues, gastrointestinal problems, bone density loss, hormonal disruptions, hair and skin problems, immune system dysfunction, depression, anxiety, social isolation, impaired cognitive function, and even suicidal thoughts and behaviors.[3]
Tens of millions of Americans are affected by EDs. Tragically, 26% of those afflicted with anorexia will attempt suicide,[4] and 5% will die within four years of being diagnosed.[5] The situation is indeed grave.
Can you solve societal problems through political grandstanding?
No doubt, we all want something to be done to alleviate the pain of those with disordered eating conditions, to cure them, and, wherever possible, help prevent people from developing these disorders in the first place. The problem, as always, is that however great our good will towards fellow human beings may be, society’s collective resources, knowledge, and experience are decidedly limited. It is thus of critical importance to see that those resources are allocated in the most effective possible manner.
With so many lives hanging in the balance – mostly young, innocent lives – the opportunity cost of wasting time and money on empty gestures is simply unacceptable, and arguably, downright irresponsible.[6] Every dollar of public money, every minute of primetime media coverage, every op-ed column inch spent on ineffective solutions depletes a finite reserve of social, political, and economic capital. It’s not difficult to argue that wasting these resources amounts to malfeasance, especially if done deliberately to run interference for special interests.
The STRIPED War On Supplements – Harvard’s Latest Potemkin Village
Enter Harvard, that impenetrable bastion of entrenched privilege and alma mater of renowned war profiteers like Henry Kissinger and convicted Wuhan collaborator Charles Leiber.[7,8]
Times have been tough for the university recently, but Harvard’s beleaguered Pilgrims soldier on. Despite the fact that Claudine Gay recently resigned amidst allegations of antisemitism and academic plagiarism, thus ending the shortest tenure of any Harvard President since its founding in 1636,[9] the university has been fighting valiantly to defend its $50 billion endowment from the families of those whose body parts were posthumously dismembered and trafficked on the black market by the then-manager of Harvard’s morgue.[10]
Given the undaunted courage and uncompromising principle that Harvard has shown in disclaiming its liability for the mass violation of human remains, we can breathe a little easier now that its Strategic Training Initiative for the Prevention of Eating Disorders (STRIPED) is taking on Big Supplement. No reasonable person could doubt that STRIPED will live up to the customary moral standard of its parent organization.
Grooming politicians and passing state legislation
The gang from STRIPED is currently all over the national media, taking a victory lap over New York State’s passage of S.5823C/A.5610D,[19-21] a bill that bans the sale of “over-the-counter diet pills and muscle-building supplements” to minors. This bill was vetoed in December, 2022 by Governor Kathy Hochul,[22] but she later passed the next version in 2023.[19] STRIPED had been lobbying for it all along.[23]
The Natural Products Association has sued New York over this law on grounds of constitutionality and vagueness (with the Council for Responsible Nutrition filing their own suit months later), and it’s currently under debate in the state’s court system.
Who is STRIPED, the group lobbying for supplement restrictions?
Run by director Bryn Austin,[24] a professor of Social and Behavioral Sciences who was also the founding director of the Sexual Orientation, Gender Identity and Expression Health Equity Research Collaborative,[25] STRIPED’s mission is to “strive to create a society where girls, boys, and people of all genders can grow up at home in their own bodies”.[26]
The organization isn’t just about dietary supplements, although that will be the focus of this article. For instance, their Advocacy Playbook not only has campaigns against dietary supplements, but also against things like liquid silicone cosmetic injections and digitally altered advertisements.[27]
A look through STRIPED’s website quickly shows the following:
- They are very well-organized
- They are extremely well-funded
- They are active
- They are persistent
- They are experienced
- They are not going to stop
Regarding STRIPED’s other activities
Note that this article will solely focus on the organization’s dietary supplement attacks, but let the record show that we’re not exactly fans of silicone lip injections either.
Dig further into their supplement campaigns, and you’ll see that STRIPED is armed with legal rationale, “scientific” summaries, fact sheets, policy briefs, talking points, and even model legislation for your state senate or assembly, right there ready to go with a simple copy-paste.[28,29] You might even notice that their model legislation “to prohibit the sale of over-the-counter diet pills or dietary supplements for weight loss or muscle building to minors” looks eerily familiar to the law that New York just passed.
Point being, this organization knows what they’re doing and they’re playing for keeps.
STRIPED contends that strategies to prevent eating disorders “need to reach young people early, before they have started down the path of escalating weight and shape control behaviors that can eventually lead to an eating disorder and other serious health problems.”[26]
Setting aside the obvious problem of imprinting ideas into children’s minds, solving health problems is generally a noble cause. But does banning supplement sales for minors actually treat any root cause conditions? Are adolescents taking diet pills in droves?
Disclaimer: An honest look at the data
Before we go further, realize that we’re not about to defend the use of diet pills for teenagers.
Later in this article, we debate whether “access to fat burners for minors” is a hill that the dietary supplement industry really wants to die on, and where the red line should be drawn.
But for the moment, we’re going to set that discussion aside and look at the data, if only to capture some semblance of truth before re-entering the reality that’s been thrust upon us.
Do “diet pills” lead to eating disorders?
STRIPED claims that the passing of the New York law is a major victory for public health, on the grounds that diet pills and muscle building supplements like creatine pose “health risks and widespread problem of adulteration with toxic ingredients”,[30] and that these product impurities have led to a significant number of adverse events.[31]
STRIPED also maintains that “Use of diet pills is considered a ‘disordered weight control behavior’ that may reflect an ongoing or developing eating disorder”,[32] failing to provide a citation for such claim.
They also state that “These products may be abused by people with eating disorders. Experts in the field have raised serious concerns about people with eating disorders abusing diet pills, including orlistat”,[32] citing a theoretical opinion piece whose abstract isn’t even on PubMed.[33]
Needless to say, orlistat isn’t even a dietary supplement – it’s a drug! As we press on, you will find that STRIPED’s co-mingling of drugs with dietary supplements is a consistent theme in their research.
With that noted, let’s look at the actual data:
Eating disorders are up, but diet pill use is down
Taking STRIPED’s rhetoric at face value, one could be forgiven for reaching the conclusion that there must be some unprecedented epidemic of illicit supplement use in teenagers. Granted, it does make intuitive sense that as eating disorder prevalence rises, teens could turn to supplements and drugs alongside extreme dietary measures in order to cope with feelings of body dysmorphia.
However, that is not what peer-reviewed data shows.
Teenage diet pill use is at an all-time low of 1.1%
Since 1975, the University of Michigan’s Institute for Social Research has conducted an ongoing epidemiological study called Monitoring the Future, which currently has data all the way through 2024.[5] Among other things, the MTF report looks at teenage use of diet pills, which are here defined as over-the-counter stimulants intended to produce weight loss. It found that diet pill use among teens “Use stabilized through the mid-1990s at around 9.4%, rose after 1998 to reach 15.1% in 2002, and then declined to today’s low of 1.1% in 2023.”[5,34]
The all-time high for teen diet pill use came in 1982, a year when a whopping 21% of teens reported taking them. Yet each year we track, this number is actually trending down![34]
So effectively, we have an all-time high in eating disorders, but an all-time low in diet pill use!
How did we reduce teen diet pill use from 21% to 1.1%? That’s an enormous drop, so what caused it?
STRIPED asserts that “there is no meaningful federal oversight” for dietary supplements,[35] but does this allegation align with the federal government’s actions?
Are supplements “inadequately regulated” by the FDA?
It turns out that the FDA has been very active in regulating and enforcing laws with respect to diet pills. A major drop in use was caused by a 2005 FDA ban of phenylpropanolamine (PPA), an amphetamine-like compound that was marketed as an over-the-counter medication, not a dietary supplement.[36] The FDA determined that PPA was causing harm, and pulled it from OTC sales.
In terms of dietary supplements, the FDA banned ephedrine alkaloids — which are found in nature — from use in dietary supplements in 2004,[37,38] and upheld by courts in 2006.[39] DMAA was similarly removed in 2012[40] and upheld in 2019.[41]
We’ve seen similar actions taken against numerous other ingredients like DMHA, DMBA, methylsynephrine, higenamine, BMPEA, and several others listed on the FDA’s “action list”.[42] Just prior to publishing this article, the FDA even sent a warning letter regarding another molecule that’s more innocuous than the above compounds, but still isn’t an acknowledged dietary ingredient (N-methyltyramine).[43]
So are supplements inadequately regulated? It seems like the FDA has been doing its job, even up to the month this was published, but let’s dig deeper:
The four pillars of dietary supplement regulation:
On this platform, we often explain the four pillars of dietary supplement regulations, as first introduced to us by Natural Products Association’s president and CEO, Dan Fabricant, in Episode #100 of the PricePlow Podcast:
-
New Ingredients: The Pre-Market Safety Process
The NDI (New Dietary Ingredient) Notification process, established by DSHEA 1994, governs how new ingredients are introduced to the market — the FDA has an opportunity to acknowledge or reject them within 75 days.[44-47]
DSHEA 1994 also allows the FDA to remove ingredients due to adulteration, which generally involves documented safety issues.[45,48]
-
Labeling Laws
DSHEA 1994 gave FDA the authority to regulate supplement labels, after which they created numerous codes with respect to ingredient listings, nutrition/supplement facts panels, and product claims.[49]
The FTC (Federal Trade Commission) also has several regulations regarding labeled, marketing, sales, and claims.
-
Quality and Manufacturing Laws
21 CFR 111 contains the Good Manufacturing Practices (GMPs).[49] Dietary supplements may be part of the “Food” category in the “Food and Drug Administration”, but these supplement manufacturing laws are really modeled after the drug GMPs in 21 CFR 210 and 211.
-
Adverse Event Reporting
The FDA uses MedWatch for the dietary supplement Adverse Event Reporting (AER) system — this is basically a “copy/paste” of the drug reporting system.[50]
We’ve also recently discussed how criminals were arrested for smuggling tianeptine, an opiate drug that’s most decidedly not a dietary supplement,[51] and covered another man’s indictment for manufacturing SARMs, which are also not dietary ingredients.
So the question is simple: in STRIPED’s view, what’s wrong with this regulatory scheme?
In 2005 through the present, it’s been working exactly the way that it’s supposed to – abuse of particular substances that do not pass DSHEA 1994’s definition of dietary supplements were identified, and the FDA took decisive action to remove them, often putting offenders in prison.
While we don’t always agree with the FDA’s actions (such as their attempt to ban a B-vitamin named NMN that they already acknowledged as a dietary ingredient), we do applaud the FDA and DOJ for rightfully enforcing their laws — and actually encourage more of it, especially at the contract manufacturing level where the products are actually bottled.
What does STRIPED really want the FDA to do?
STRIPED criticizes the FDA for failing to take more action in 2024, but has yet to rigorously identify the scope of the problem that the agency actually needs to solve. Since we believe in the scientific method, we checked out STRIPED’s summary of the evidence supporting their position that dietary supplement sales need to be restricted by age.[52]
Overall, this research summary is thoroughly unimpressive. It includes studies that demonstrate the following:[52]
- There are banned substances in some supplements
- Voluntary recalls are not an effective enforcement mechanism for removing tainted products from the market, and
- Some teens use dietary supplements.
While we definitely agree that tainted products are a huge issue, and constantly lobby the FDA and Department of Justice to take the strongest possible legal action against companies that sell them, this is a matter of enforcement, not rulemaking. As detailed above, the laws against adulteration already exist.
It’s worth repeating that STRIPED cites theoretical research on a drug (Orlistat)[32,33,52] while attacking dietary supplements, and the biggest drop in diet pill use came after the FDA removed a drug (PPA) from the market.
Something isn’t adding up.
The NPA’s FOIA Request: Adverse Events and Eating Disorders
When STRIPED’s lobbying efforts began pushing a connection between diet pill use and eating disorders — nearly implying causation by claiming that weight loss products and supplements are “a gateway to steroid use and eating disorders”[53,54] — the Natural Products Association filed a Freedom of Information Act (FOIA) request to see what data the FDA had on the matter.
Their FOIA request requested from the FDA “Any dietary supplement adverse events tied to or that mention eating disorders (i.e. anorexia, bulimia, binge eating, etc.)” from 2018 through 2022.[55]
The FDA’s data turned up zero adverse events for weight loss supplements in people with eating disorders![56] Instead, it consists of products like calcium + vitamin D3 tablets and an eye supplement with exceedingly high mineral content.[56]
Admittedly, absence of proof is not proof of absence, but there’s still no data to back STRIPED’s assertions up.
Hand in Hand: STRIPED and Logical Fallacy
Putting STRIPED’s premises together simply does not lead to evidence that teens are being harmed by tainted dietary supplements. The recent data actually shows the opposite.
At best, these premises only demonstrate the potential for harm, which is why we do want the FDA to rigorously audit both drug and supplement manufacturers. That’s also probably why there’s not a single study in the STRIPED summary that demonstrates harm to minors.
Mechanistic reasoning
In nutritional and medical science, one of the most common fallacies is to cite a mechanism as evidence of benefit, rather than a randomized controlled trial that demonstrates a positive outcome. In other words, it’s fine that aspirin downregulates inflammation via COX-2 inhibition, but the existence of that mechanism does not necessarily mean that aspirin will be useful for all inflammation-related conditions. Insisting otherwise is known as mechanistic reasoning, a type of analysis that’s generally frowned upon.
We submit that STRIPED is making exactly the same type of false inference about harm from dietary supplements. It’s great to do studies demonstrating that dangerous substances are showing up in some supplements and that some kids are taking some supplements. However, even if one grants those premises, it does not logically follow that these supplements are harming kids. In order to prove that, you’d need to do research demonstrating the outcome of harm to minors from supplements – anything short of that is speculation.
Yet STRIPED, with all the impressive resources and credentials at its disposal, can’t even produce a single study supporting their central point. This is especially surprising in light of one particular study, which is cited ad nauseam by anti-supplement social justice activists, showing that from 2007 to 2016, the FDA identified 776 different widely available supplements that were contaminated with one or more unapproved substances.[57]
This is the most compelling evidence that STRIPED has mustered in defense of its crusade against “diet pills”, so it behooves us to take a close look at what this study really tells us.
With over 100,000 dietary supplements available for sale in the United States,[58] this represents 0.78% of products for sale — but the actual scale of the problem is even smaller because such adulterated supplements come from fly-by-night companies or get pulled from the market quickly by the FDA, as evidenced above.[42]
The other study cited by STRIPED that talks about documented harm was with respect to the fat burner OxyELITE Pro,[59] whose formulators replaced DMAA with known liver-toxic ingredients and were subsequently indicted and imprisoned for it.[60,61] Several others were also imprisoned for faking COAs (Certificate of Analysis) upon import, although many of those arrests did not make public news.
Why the selective enforcement?
Our question to STRIPED, but more directly to the FDA and Department of Justice, is why there weren’t more brands and/or manufacturers put in prison throughout those years? If laws were so badly broken (apparently at least 776 times), why wasn’t more done about it?
The government’s current position seems to be that justice only gets served after people get hurt — something that we and STRIPED could both agree is insufficient. Even Harvard’s own Pieter Cohen, dubbed the “Grim Reaper of ‘Gray Area’ Ingredients”, has called the FDA’s lack of usage of enforcement tools a “Dereliction of Duty”.[62]
It’s also worth noting that the dietary supplement industry has cleaned up leaps and bounds since 2007. The growth of the industry, establishment of numerous certifications that go beyond cGMP compliance, and entrance by big corporations has made sure of that.
Using data from the 2000s to attack today’s industry is downright laughable to anybody operating within the space, although the industry needs to do a better job of communicating this. Any studies that have shown adverse events from the 2000s[63] should be re-done with data from the 2020s — it’s almost guaranteed that you’ll find significantly fewer problems now, especially since use is lower:
What diet pills? Capsule sales are down
Further, anyone in the supplement industry is well aware of the fact that the “diet pills” market has been shrinking, even without seeing Michigan’s data.[34] All capsule-based sales have been shrinking over the past decade,[64] and that’s based on data taken before the Ozempic fad further cut the market down.
Finally, if you know any adolescents these days, you’ll know that a majority of them couldn’t even be bothered to mix a shake, let alone consider taking a pill. If it’s not in a ready-to-drink beverage, there’s a good chance they’re not even going to bother.
Put simply, the FDA has firmly eradicated any weight loss stimulant from the market that would potentially “go viral” in the community, and demographic consumer shifts have occurred that are exactly counter to STRIPED’s thesis on “diet pills”.
There’s clearly more to this situation than meets the eye.
Enter the war on creatine
But is this all just about diet pills? The answer is no — diet pills, as STRIPED likes to say, are merely the “gateway”. Or, in our estimation, they’re the beachhead for a larger attack on the industry.
So what exactly are the other terrible substances that STRIPED wants to keep out of childrens’ reach? Their summary sheet is careful to point out that according to a 2006 survey, a horrifying 5% of teens had used – wait for it – creatine![52]
A brief background on creatine
Despite what the mainstream media may have impressed upon you, creatine is decidedly not a steroid — or anything remotely close. It’s a molecule found naturally in food and stored in muscle tissue (as creatine and phosphocreatine) to support cellular energy production.[65,66] These molecules contain precious phosphate groups that get shuttled to create ATP,[67,68] the body’s true energy source.
The body can create its own creatine if you don’t ingest any, but that’s metabolically expensive and burdensome,[69] taking resources from other critical biological processes. This is why we supplement the diet with it.
There’s absolutely nothing “hormonal” going on here; when taking creatine (or eating food rich in creatine), you’re merely providing your cells with more tools to generate usable energy. This has been studied and known for decades now.
This is also why creatine’s long been used as a beneficial dietary supplement confirmed in numerous meta-analyses and systematic reviews to not only improve muscle health,[70-74] but cognitive health as well[75,76] (especially in vegans/vegetarians[77-80]) — and with practically no safety concerns.[81-83] There one possible safety caveat is for individuals with pre-existing kidney disease,[84] but even that’s up for debate.[85] A recent study even demonstrated that single dose creatine improves cognitive performance during sleep deprivation![86]
Ultimately, having researched the molecule enough, we can confidently say the following: Anybody who wishes you to stop ingesting creatine — be it through food or supplementation — is wishing weakness, lethargy, and poor cognitive performance upon you. Whether they know that or not is another question.
With that said, there’s less research on creatine for adolescents. Let’s get into that next:
STRIPED’s Evasive Take on Creatine for Adolescents
You’ll notice, if you take a look at the STRIPED summary sheet yourself, that the organization stops short of asserting creatine harms children. That’s because there’s no evidence it does.
The best the organization can do is to claim that “muscle-building supplements may lead to increased risk of testicular germ cancer in men”,[52] citing a 2015 study on men in Connecticut and Massachusetts.[87] The only problem there? The study included users of androstenedione, a steroid prohormone drug known as 4-androstenedione that converts to testosterone and is toxic and carcinogenic![88]
Once again, STRIPED is attacking one dietary supplement using research on a dangerous prohormone that is most decidedly not a dietary supplement! Talk about poisoning the research well.
Getting to some actually serious science on creatine, one research review on the subject, published in 2018, reports the following (emphasis ours):[89]
“The results of our systematic review revealed that no studies to date have been completed that sought to directly examine the safety of creatine use in an adolescent or youth population. Subsequently, each efficacy study in adolescents was closely reviewed by the authors to ascertain any information that might be present regarding any clinical side effects resulting from creatine use in adolescents. In this respect, none of these studies observed any gastrointestinal discomfort or changes in hemodynamic, urine, or any blood markers of clinical health and safety following the supplementation periods.”[89]
A more recent review looking at creatine in adolescents that was published in 2021 summarizes the following:[90]
“studies involving creatine supplementation and exercise performance in adolescent athletes generally report improvements in several ergogenic outcomes with limited evidence of ergolytic properties and consistent reports indicating no adverse events associated with supplementation”.[90]
Another review discusses several individual pediatric studies on various disease states, all with positive outcomes and no adverse events.[91] It states:
Several of these clinical trials implemented strict clinical surveillance measures, including continual monitoring of laboratory markers of kidney health, inflammation, and liver function; none of which were negatively impacted by the respective creatine supplementation interventions. These findings support the hypothesis of creatine supplementation likely being safe for children and adolescents.[91]
Creatine monohydrate is FDA GRAS
The above review goes on to mention that in 2020, the FDA itself formally approved creatine monohydrate as GRAS — Generally Recognized as Safe.[92-94] Note that this is an actual FDA GRAS notice, not a company’s GRAS self-affirmation. While GRAS affirmation isn’t enough to put it in infant formula, it certainly does apply to foods available to adolescents.[95]
We’ll conclude this section with one last example — a 2021 study showing that dietary intake of creatine from food leads to taller children and adolescents.[96]
A dose of how these lobbyist organizations work
So why is STRIPED mentioning creatine in their summary? The answer, unfortunately, seems to be that the organization is engaging in some very deceptive rhetorical sleight of hand. One of the research reviews cited above continues (emphasis ours):
“It is worth mentioning that some individuals point to the warnings provided on product labels that individuals younger than 18 years of age should not take creatine and inappropriately extrapolate this as evidence that creatine supplementation is unsafe in younger populations, rather than acknowledging there are insufficient data to confirm the need for such warnings. These warnings are not scientifically-based and are provided more as a legal precaution.“[89]
This creatine example illustrates how organizations like this advance their agenda. Not by reasoned scientific argument, but by innuendo, suggestion, logical fallacy, and emotional string-pulling.
They maintain plausible deniability by stopping short of explicitly asserting that creatine is harmful to minors, and instead merely imply it, knowing that the vast majority of people, if they bother trying to verify this assertion at all, will find the legal disclaimers and assume that they’re based on science. Those warnings are, emphatically, not science based. But the career sophists that line the halls of academia want your brain to make that false deductive leap on their behalf.
Creatine now banned to minors in New York
The reason we’re bringing this up is that according to the new law STRIPED just pushed into law in New York, creatine can no longer legally be sold to minors there.[19] The bill’s definition of dietary supplements for weight loss or muscle building defines them as any dietary supplement “labeled, marketed, or otherwise represented for the purpose of achieving weight loss or muscle building,” excluding supplemental dietary protein.[19]
This means that New York State has just, in lieu of any supporting evidence, banned a cheap, safe, and incredibly effective nutritional supplement for sale to minors. And it’s one that truly provides benefits given our societal dietary movement away from creatine-containing foods.
Loose language laws
The absurdity of this law’s regulatory approach can be illustrated by a simple thought experiment: What if creatine, despite the hundreds of studies backing its use for fat loss and muscle gain, had never been marketed as a product for those purposes, but instead as a “cellular energy” product? That is what it really is, after all. Well, in that case, creatine would not be banned for sale to minors by this bill.
This “logic” creates a precedent for serious abuses. For example, if any pharmaceutical or supplement company wants a certain product banned for sale to minors, all that company needs to do is market it themselves as a fat-burning or muscle-building supplement. Once that’s done, voila – the supplement’s legal status has been changed by corporate fiat. It is now technically illegal to sell to minors in the state.
As a corollary to this, any supplement that’s ever been connected to a fat-burning or muscle-building claim is now vulnerable to being more or less summarily banned. This includes not only creatine, but also B vitamins, amino acids, and dietary fiber supplements like psyllium husk.
Again, our objection is not primarily an argument in favor minors should be taking these supplements – it’s an argument against regulatory schemes where the legal status of supplements can be arbitrarily changed by online ad copy.
Circumventing Federal Law: A sneaky old trick becomes new again
The enormity of this shift cannot be understated. STRIPED is advocating for a system where scientific evidence is not used to determine the legal status of dietary supplements, all while the federal government already has laws pertaining to their regulation. In other words, it makes no difference whether a supplement you’re selling is backed by evidence or not. It’s the claims that matter.
So what do you do as a lobby organization when the federal government’s constitutional laws actually work by sticking to scientific basis and not emotion, yet aren’t to your liking? One method of the many you can employ is to find impressionable and ambitious politicians in your tribe and get them to pass state laws that circumvent federal law.
A 2015 paper co-authored by Bryn Austin providing legal strategies for state government intervention outlines it quite clearly, stating that when Congress passed DSHEA 1994, it rendered “regulatory controls too weak to adequately protect consumers” and that “State government intervention is thus warranted.”[97]
Whether such an approach is “unjust” or not, however, can be decided by the courts later. And surely they have ways to handle that as well…
Affirming the consequent
Getting back to STRIPED’s persistent use of logical fallacy, there are two studies that the organization loves to cite when attacking dietary supplements — nearly as much as the ones discussing drugs like Orlistat[32,33,52] or androstenedione steroids.[52,87] They are the following:
-
Performance Enhancement “Substances” Correlate to Steroid Use[98]
This study found an association between those who use steroids also using performance enhancing “substances”.[98]
Note the use of the word substances instead of supplements. Why? Because this study wasn’t just about creatine — it also included androstenedione! Once again, the data well is poisoned by the inclusion of a steroid prohormone that’s not a dietary supplement.
Of course, STRIPED has no problem citing it anyway.
While those of us who actually read studies can chuckle at the conclusion that “steroid use is correlated with steroid use”, poorly-constructed research like this makes for great headline material in sensationalist corporate mainstream media news pieces – and the dietary supplement industry is left without a rebuttal.
But even ignoring that clear confound, the conclusion shouldn’t be a surprising correlation. Anyone who’s willing to take steroids is going to want more creatine in their skeletal muscle tissue.
-
Diet Pill and Laxative Use Predicts Eating Disorder Diagnosis[99]
This study, co-authored by STRIPED director Bryn Austin, found a correlation between use of laxatives and diet pills with the future receipt of an eating disorder diagnosis.[99] Again, not a completely surprising correlation, but that’s not the full story.
Digging deeper, the data presented here was based upon a non-validated survey, where the determination of whether one used “diet pills” was made from the following loaded question:[36,100]
“We would like you to tell us about any other products that were NOT prescribed by a doctor that you have taken to control your weight, including over-the-counter products such as pills, powders, and liquids. This includes dietary supplements and natural or herbal weight loss aids not prescribed by a doctor. Have you ever taken any of these products to control your weight?”[36,100]
The response categories for all of the questions in that survey were:[36,100]
- “Yes, in the past 12 months”
- “Yes, but not in the past 12 months”
- “No”
Once again, we have data whose well is poisoned by drugs — the convoluted question doesn’t bother to define the differences between dietary supplements and OTC drugs! It’s the same ridiculous tactic every single time!
Beyond the obviously tainted nature of these studies, they’re also both perfect examples of the adage, correlation does not equal causation. All they do is illustrate a statistical association between two variables. There are even more examples of these methodological flaws in Susan Hewlings’ 2023 article, “Eating Disorders and Dietary Supplements: A Review of the Science”.[36]
The implied causality is simple to see through, and realizing that, it doesn’t actually mean anything. It is akin to the following train of thought:
- “If it rains, then the ground is wet.
- The ground is wet, therefore it has rained.”
This is a logical fallacy known as affirming the consequent.[101] “If A then B” does not imply that “If B then A”, no matter how hard you try. This fallacy occurs when one assumes that because the consequent (B) is true, the antecedent (A) must also be true. That’s invalid and downright fallacious to use in any setting, let alone a scientific one.
Lobbyist organizations like STRIPED want to live in a preponderance of evidence type of world, but no matter how hard one works at piling up correlations, it doesn’t change the rules of logic.
Their response to such a situation is, “Well, you can’t do a randomized controlled trial on this”, and the answer to that is “Yes, that’s correct, and that’s why you have no business banning anything on the basis of poorly-controlled correlational studies”. Especially when it flies in the face of federal law.
They so very much want “prospective” to mean “causal”, and it simply doesn’t.
Yet, as we’ll discuss in the conclusion, it also doesn’t matter, given that perception is reality, and right now, they are controlling the perception.
A 20% Excise Tax on Supplements?!
Amazingly, the bans on minors aren’t even the most draconian proposal on the STRIPED agenda.
The organization also suggests that lawmakers impose a 20% excise tax on all “over-the-counter diet pills”,[102,103] a definition that can, in practice, be easily expanded to include all dietary supplements.
That’s right – no matter how responsible a supplement manufacturer, no matter how clean their facility, how pure their products, how reliable their third-party batch testing, they will be forced to deal with a 20% excise tax on potentially all their products in every state where STRIPED’s lobbying prevails.
This proposal has nothing to do with regulation. It’s a barely-disguised attack on the supplement industry as a whole, and they’re going to push to sweep it through state after state on the coastlines.
The most charitable interpretation of these proposals is that they’re a waste of society’s collective resources. Put simply, the people who belong to STRIPED are fundamentally unserious people, at least with respect to science. They’re quite serious about other things, however.
The less charitable, and more likely interpretation, is that this is yet another institutional power grab, masterminded by managerial elites who are acutely aware of the fact that their status will only rise in a fully-permissioned society. That means they have a clear incentive to end all over-the-counter sales of anything that could be “properly” regulated by the FDA, and prescribed by a physician.
Solutions of blanket bans and taxes are, quite simply, not good faith solutions.
If Harvard University, the center of the universe, really cared about curbing widespread harm to children resulting from the use of tainted dietary supplements – harm which Harvard has not offered a shred of real evidence to demonstrate – then it would use its massive endowment to take or support legal action against truly problematic drugs being aimed at adolescents:
Where is STRIPED on cosmetic and diet drugs that actually cause harm?
If STRIPED was operating in good faith, then they would be all over problematic drugs like isotretinoin, the heavily-prescribed acne drug sold as Accutane.[104]
Scientifically known as 13-cis-retinoic acid, this is a vitamin A metabolite[105,106] whose side effects range from inflammatory bowel disease[104,107,108] to headaches[107-109] to depression,[104,110,111] all the way to suicide ideation and attempts![104,110,112-114] It’s so horribly toxic, women are told to use two forms of birth control while on it, due to its notoriously teratogenic (birth-defect causing) nature.[104,115-118]
This incredibly-damaging drug is frequently over-prescribed to teenagers,[112] often leaving them with lifelong side effects or years of intense retinoid detoxification. Isotretinoin’s counterpart, tretinoin (sold as Retin-A), doesn’t fare much better.[119,120]
But a thorough search of STRIPED’s website shows no mention of the words “Accutane”, “retinoic”, “tretinoin”, or “vitamin A”.
What about GLP-1 agonists like semaglutide (Ozempic)?
Or, striking closer to home, shouldn’t we expect similar hostility from STRIPED regarding prescription GLP-1 agonists like semaglutide (sold as Ozempic)? After all, a study on obese adolescents using it just once weekly noted side effects so severe that a whopping:[121]
- 62% developed gastrointestinal adverse events
- 11% of participants had “serious adverse events”, and
- an astonishing 4% of semaglutide users developed gallstones (cholelithiasis)![121]
These are numbers quite unlike any dietary supplement or even OTC diet pill drug we’ve ever seen!
To STRIPED’s partial credit, a former team member of theirs, Amanda Raffoul, was quoted in Teen Vogue saying the following:
“Right now, [Ozempic is being called] this miraculous weight loss drug. That type of conversation masks the health risks of taking a product like Ozempic, and it reinforces this cultural narrative that you have to be thin and doing anything you can [to get there].”
“For young people who are not taking Ozempic … they might see their favorite celebrities talking openly [about using it] and think, ‘well, I’m going to try and find ways to achieve that body as well.’ That dialogue contributes to things like berberine being really popular.”[122]
However, Raffoul no longer seems to be with STRIPED (correct us if we’re wrong), and their website’s only mention of this article is on their news page, which only states:[123]
“In this Teen Vogue article, STRIPED’s Amanda Raffoul highlights the potential health risks posed by largely unregulated weight loss supplements like berberine, which are becoming popular alternatives to prescription drugs like Ozempic for weight loss purposes.[123]
Now that’s interesting. Did you notice the soft, omissive language used on the STRIPED website when referencing that article?
Given their mission to “strive to create a society where girls, boys, and people of all genders can grow up at home in their own bodies”,[26] shouldn’t STRIPED want adolescents off of such toxic drugs — drugs whose side effects greatly surpass anything the dietary supplement industry has ever produced?
If so, then we can start working together on nutrition, cleaning up the ultra-processed, poisonous mess that has been thrust upon our society, especially towards minors.
Waiting for updates
We’ll gladly update this article if STRIPED’s approach changes, but we’re not holding our breath. Our guess is that they won’t take action on these and other dangerous drugs… because this quite likely isn’t a good faith attempt at solving the root of our nutrition problems. It’s instead a well-intentioned, well-organized, and well-funded attack — and the dietary supplement industry is not even remotely ready for it.
Living in a Post-Truth World
Now here’s the kicker: In reality, the 6,500+ words of text above this don’t matter.
As scientific, truth-seeking individuals (a character type that makes up a great deal of the supplement industry), we strive to base our decisions around as much scientific rigor as possible. We understand that correlation does not equal causation, we understand that diet pill use is dramatically down, and we understand that creatine is not a hormone.
But if we can’t deliver that message, while the opposition can deliver theirs, then we are on the losing end of a purely-defensive battle.
Organizations like STRIPED have money-printer-level funding, with which they can run obscenely ridiculous studies, torturing the data until it confesses statistical lies, then have it published in basically any major journal. They’re incredibly well-connected — especially when run from Harvard — and can get nearly anything placed onto mainstream television news programs. Representatives of the dietary supplement industry are lucky to get a comment on the last paragraph.
This is not a scientific argument
The problem with this entire situation is that it’s not even a scientific argument. It’s a political one. And the dietary supplement industry is decidedly not good at politicking.
We act like there’s some burden of proof that STRIPED has to satisfy before they’re granted permission to destroy an entire industry. We ask questions like, “does epidemiological causal inference justify this kind of regulation?” while they simply go and make dramatic headlines and get their friends to pass laws in friendly states.
The story of modern public health policy is basically the government screwing up one thing after another by relying on this type of inference to write regulations, and here it is, the barrel of that shotgun staring right down upon us.
There will be no logical argument here
Ask yourself and answer honestly — do you really expect to have a reasonable and logical discussion with someone who refuses to acknowledge the stark difference between creatine and oral steroid prohormones like androstenedione?
Let’s be real here: There will be no rational debate with this level of preposterous behavior.
We like to discuss evidence and statistics, because we want to make sure that we’re right. But to assume that someone who wants to destroy you is also a truth-seeking individual — just because you are — is laughably ignorant.
But these are not truth-seeking individuals. They are instead, either:
- Power-seeking individuals,
- Rent-seeking individuals,
- Or merely funded by those who are a mixture of the above two.
In such a world, your “truths” don’t matter. Only victory does. And they are currently the victors, at least in New York. The dietary supplement industry needs to figure this game out fast.
The dietary supplement industry is unprepared for this level of warfare
Bryn Austin has been at this for quite some time, having co-authored a paper suggesting the ban of over-the-counter drugs and weight loss supplements as early as 2013.[124] That paper focused more on Orlistat and other OTC drugs than supplements, but the lesson for you here is that these people play the long game. It may have taken her a decade, but Austin got her New York win, and she’s not stopping anytime soon.
So, our question to anyone in any position of authority in the supplement industry: are you really ready for this over the long haul? Because like it or not, you’re up against professionals. She’s been at it for at least 10 years, and she’s got at least 10 more. Do you? Or are you just going to job-hop every three years and let someone else get run over by her?
What is your hill to die on, and is it weight loss pills for adolescents?!
Let’s call a spade a spade. STRIPED is very, very good at this. Because they’ve found the perfect precedent-setting issue that’s embarrassingly hard to defend.
By attacking weight loss pills for minors in friendly jurisdictions, they’ve effectively put the dietary supplement industry on its back, and now they’re taking creatine with it.
You need to ask yourself: Are you willing to die on the “16 year old girls should be able to buy stimulant fat burners” hill?
Because we, quite frankly, are not.
After all, we don’t want our adolescent daughters taking this stuff either.
And therein lies the issue. The entire setup leads us to a massive problem: the slippery slope. You’ve already seen it begin with creatine and potentially several other health-beneficial amino acids. By giving up this one little thing, you are priming yourself to give up the next. And the next and the next after that. Constantly playing defense, bit by bit, until your industry is a shell of its former self. Exactly to plan.
So the current choice is to fight these laws on constitutional grounds, but if those efforts fail, where will you draw your red line? Because, let’s be honest, “stimulant fat burners for kids” is probably not the place to draw it. But is creatine? We actually think so.
It is time for the industry step it up
Sadly, however, the supplement industry has provided far too little high-quality data with respect to creatine for children or adolescents (not that data matters to the opposition, but it could help those on the fence). This is despite the fact that some brands are obviously doing quite well selling creatine in products that mom often buys for her high school son at Target and Walmart.
This kind of study is rarely done because it can’t be marketed to kids, despite the knowledge that it can help kids. And now, by allowing your products to be sold to minors but not studying their effects, you’ve opened the door to a Trojan Horse attack, with little data to defend it.
The industry’s foot-shooting problem
Meanwhile, STRIPED has everyone on the defensive, and the supplement industry can’t even get together long enough to file a lawsuit properly. Instead, three months after one organization originally filed their lawsuit against New York, another organization filed theirs — in a separate district, no less.
While we’re at it, it’s probably time to have an honest discussion about some of the known-carcinogenic synthetic ingredients still used in nearly every multivitamin, despite meta-analysis after meta-analysis demonstrating increased mortality, cancer, and bone fractures,[125-132] with more data mounting on rheumatoid arthritis and early cancer deaths,[133,134] despite being “FDA GRAS. Even worse, it’s frequently used in high doses for “natural colors” (despite being synthetic), in which cases the guidelines don’t even require its nutritional value to be disclosed.
If the FDA isn’t going to do anything about things like this, it’s time the industry did something itself — before organizations like STRIPED use it to further their advantage.
All told, they’re laughing at you, they’re laughing at us, they’re laughing at everyone… and they’re winning.
It’s time to understand what you’re up against.
Who’s funding STRIPED?
So what is the industry up against, financially speaking? Taking a look at STRIPED’s current funding,[135] you find some highly interesting sources of revenue, starting with the U.S. Department of Defense!
Additional federal funding comes from the National Institutes of Health, via the Ruth L. Kirchstein National Research Service Award, and even more federal funding from the U.S. Maternal and Child Health Bureau.
Now, why, you might ask, is the US Department of Defense funding an attack on the dietary supplement industry? Especially when their recruits could decidedly use a bit of nutritional support,[136] to say the least. Your guess is as good as ours.
But when you have one arm of the federal government supporting an organization that’s working to circumnavigate the laws of another arm of the federal government, you’re probably not in a good place.
There’s additional funding from the Boston Children’s Hospital, where Bryn Austin is connected, and Canadian Institutes of Health Research.
Corporate funding comes from the Dove Self-Esteem Project, a group focusing on kids’ body confidence and making social media safer.
Last, there’s funding from the Becca Schmill Foundation, a youth advocacy organization that was started after Becca Schmill died of fentanyl overdose from drugs bought via social media. Their focus is on substance use disorder, sexual assault, cyberbullying and social media.
Given STRIPED’s other missions, some of these funding sources make sense, but one has to question if the federal government should be funding organizations that are working to subvert other parts of the federal government.
In the here and now, alarm bells should be sounding when you see the DoD on the funding list of an organization that seeks to dismantle you, and you better pull it together.
Something is broken, and the kids know it
Truth be told, we long for the days when Jessie Spano’s abuse of caffeine pills in the 1990 “Jessie’s Song” episode of Saved by the Bell was a big deal.[137] (For the record, that episode was originally scripted to be about amphetamine abuse, but they weren’t allowed to talk about that.[138]) Yet nowadays, a staggering number of adolescents are so sleep-deprived and metabolically-deranged that they can hardly survive a day without a full dose of amphetamines or multiple energy drinks throughout.
There’s obviously something quite wrong happening here, and stimulant addictions are but a symptom to that problem. The kids are decidedly not alright — and intuitively, they know it.
This makes the entire “STRIPED vs. Supplements” exercise is a massive distraction, because the existence of eating disorders and weight loss pills are both symptoms of a greater issue, not the actual causes.
Everything is wrong. Literally everything.
People love to argue about what’s causing the pervasive health issues in our society: “It’s social media!”…“No, it’s the screen time!”…“No, it’s the seed oils!”…“No, it’s the glyphosate!”…“No, it’s the GMO carbs!”…“No, it’s the CDC immunization schedule!”…“No, it’s tap water!”…“No, it’s the microplastics!”…“No, it’s the pollution in the sky!”…“No, it’s the seed oils!”…“No, it’s the retinoids!”
Here’s a better idea: It’s all of it!
There’s no one thing that’s ruined our societal health. It’s everything.
We call this “The Great Poisoning”. And quite frankly, organizations like STRIPED and the dietary supplement industry alike are overpowered in dealing with it, often making the situation worse.
We’re at a point in this nation’s corporate experiment where quite literally everything is toxic by default. You have to work your tail off to abstain from the damaging effects of the norm; if you’re in the middle of the bell curve, shopping the processed center of the grocery store, then you are very unlikely to be healthy.
Evidence of this is a 2019 study that showed that 88% of Americans are metabolically unhealthy (based upon waist circumference, glucose, blood pressure, triglycerides, and HDL cholesterol) using data from 2009–2016.[139] A decade later, we can absolutely guarantee you that the number is worse now.
The problem for the youth, however, is that the decision to avoid the unhealthy median is really an adult’s decision.
What chance do kids have if they’re subjected to bowl after bowl of fortified slop, only to end up obese, eczematous, and acne-ridden by the time they’re 15 years old? This is a time when they should be glowingly beautiful, vibrant, and active — and instead, they’re defeated shells of their predecessor generations.
Then once you throw the gasoline of social media and AI on the fire, and you have yourself a raging inferno of dystopian joylessness.
So what’s a kid to do when they desperately want to be healthy and energetic, but the definition of “health” has been so distorted and the food provided to them is downright poisonous? It’s a desperately sad situation.
Treating symptoms: short-term success and more problems
The point is, eating disorders and weight loss pills are symptoms of this same societal problem, not causes, and that’s what makes this entire debate a distraction.
Because while we’re bickering over causality of eating disorders and weight loss pill use, the true criminals are still polluting nearly everything, and it’s almost impossible to keep your head above the polluted waters.
Final comments to the industry
It’s increasingly clear that the dietary supplement industry is not up to speed on its history, because we seemingly couldn’t see Bolshevik-style subterfuge if it hit us in the face.
This is the problem with an entrepreneurial-minded industry: We scoff at centralized operations, acting like we’re still in the free-market, decentralized, truth-seeking world that left us decades ago. We still act like high-ranking Senator Orrin Hatch is still around to protect the law he wrote, yet he’s not. We’re vulnerable, but everyone’s fat and happy, so nobody does a damn thing until it’s time to play defense — and by that time, it’s too late.
Where are the industry’s talking points? Where is the outreach? Where’s the industry’s model legislation? Where are the media contacts? Look at the STRIPED playbook, and see how organized they are — and then see how unorganized the supplement industry is. There are what, five different trade associations?! They can’t even file pivotal lawsuits together?
The situation worsens when the fastest-growing companies nowadays are fronted by social media influencers, most of whom are unable or unwilling to get muddy in these waters. Every time a YouTube sensation’s energy drink market share grows, our industry becomes that much more vulnerable. There are rare exceptions to this, but they are just that, exceptions.
And as much as we’re proud of our work here at PricePlow, if Mike and Ben, two small-business entrepreneurs with no letters behind their names, are the guys making the most noise about an issue this big, then you’re in some serious trouble. We need more firepower, and the main organization that’s been able to hold STRIPED off for this long is NPA. So if nothing else, brands, suppliers, and retailers should consider joining the Natural Products Association (with whom PricePlow is a media partner).
You may not want to get political, but political is about to get you. It’s time the dietary supplement industry collectively started self-policing, cleaned up its act, found its red line, and started defending it, otherwise it’s about to have its ass handed to itself on a platter.
Comments and Discussion (Powered by the PricePlow Forum)