Where your supplements actually come from: What U.S. import data reveals

Opinions expressed by Digital Journal contributors are their own.

U.S. labeling rules let a supplement bottle carry a domestic address without naming the facility that made it. Customs data fills part of the gap – and shows an industry whose upstream inputs are substantially imported even when the finished product is assembled at home.

Ask an American shopper where their vitamin C came from and most will say “the drugstore.” Ask the same question of the supply chain and the answer is considerably more specific, considerably further away, and almost never printed on the bottle.

The label does not have to say where it was made

Federal labeling rules for dietary supplements under 21 CFR 101.5 require a product to carry the name and address of the manufacturer, packer, or distributor. The word is “or.” That address does not necessarily identify the facility that blended and encapsulated the product, although separate country-of-origin marking requirements may apply to imported goods.

The Federal Trade Commission does police the stronger claim: under the agency’s Made in USA Labeling Rule, an unqualified “Made in USA” claim generally requires a product to be “all or virtually all” made in the United States. But “Made in the USA” is a voluntary claim. When a label does not make that claim, the company address alone may provide little information about where the product or its ingredients were manufactured.

What the import data actually shows

Trade statistics fill part of the gap the label leaves open. Two customs categories matter most to this industry.

HS heading 2936 covers provitamins and vitamins in bulk, the raw material behind a large share of the tablets on U.S. shelves. According to 2023 trade data compiled from international trade statistics, China supplied approximately two-thirds of U.S. imports under that heading by value, or about $812 million of an approximately $1.2 billion total. No other supplier came close.

HS heading 1302 covers vegetable saps and extracts, the botanical side of the business. There the picture is more distributed: 2023 data for the category shows that India supplied approximately 28 percent of U.S. imports by value, while China accounted for approximately 19 percent, with the remainder spread across numerous origins.

Neither figure tells you what is inside any particular bottle. Together they describe an industry whose upstream inputs are substantially imported even when the finished product is assembled domestically, and an industry in which “where was this made” is a question with at least two different answers depending on whether you mean the powder or the capsule.

The marketplace layer

Online marketplaces compress that supply chain further. A brand can commission a white-label formula from a contract manufacturer, arrange for finished goods to be shipped into a U.S. fulfillment network, and sell them under its own name. The listing carries a company name and a U.S. address. Both may be accurate. Neither is necessarily informative about origin.

This is not inherently a quality problem, plenty of overseas facilities run to a high standard, and plenty of domestic ones do not. It is a traceability problem. When a consumer cannot identify the manufacturing facility, they cannot evaluate it, and neither can a retailer conducting due diligence on a new listing.

Pressure is building on the documentation side

Marketplaces have begun tightening what sellers must show. Under Amazon’s dietary supplement policy, sellers must work with an authorized third-party testing, inspection, and certification provider to verify notified products. The policy also specifies documentation and compliance requirements that may include testing results and evidence that a product meets applicable manufacturing and quality standards. Certificates of analysis tied to particular products or lots, along with information about the manufacturer, can provide buyers with additional evidence about identity, composition, and supply-chain traceability.

Those requirements do not change the labeling rules. They change the paperwork, which for practical purposes is where origin becomes visible.

The vertically integrated alternative

One response from the manufacturing side has been to shorten the chain rather than document a long one. Firms that perform botanical extraction and finished-product manufacturing in the same domestic operation, among them Florida-based AMPEXT, can trace a finished capsule back to an incoming raw botanical without crossing a corporate or customs boundary in between.

That structure can cost more per unit than buying finished extract powder on the open market. Its potential advantage is a shorter, more readily documented answer to the origin question, one that may be useful when retailers, regulators, and marketplaces review a product’s supply chain.

Three questions that separate claims from facts

1. Who manufactured this, and where is the facility located? Dietary supplement manufacturers, packers, labelers, and holders are subject to the current Good Manufacturing Practice requirements in 21 CFR Part 111, which cover areas including quality control, production records, specifications, and product testing. Identifying the facility allows a buyer to request documentation relevant to those requirements.
2. Is the active ingredient extracted in-house or purchased as finished powder? This distinction determines how many hands the material passed through.
3. Can I see a certificate of analysis for this lot? How quickly a company produces one is itself a data point.

None of these questions requires a change in the law to answer. They only require someone to ask.