NSF Labs and the Amazon Dietary Supplement Policy: Q&A

Q: What tests and methods are required for the Amazon dietary supplement policy?

A: All testing requirements including methods and limits for each contaminant and adulterant required can be found in the most recent version of NSF/ANSI 173. Pesticide testing according to USP <561> or NSF/ANSI 173 is required if the product servings contain botanicals that would be 5g or more per day. Label claim verification is also required when test methodology is available. This may include a test to verify the quantity of a claimed component or to confirm the identity of a component. Methods for label claim testing must be scientifically valid and fit for purpose.

Q: When providing a test report from a third party to demonstrate compliance, what should a Certificate of Analysis (COA) report contain?

A: Any provided COA should contain contact information for the laboratory, reference to holding an ISO 17025 accreditation, parameters tested, results, units, specifications, and method reference. All COAs must also be no more than six months old.

Q: What is ISO 17025 accreditation and why does it matter?

A: ISO 17025 is an international standard that is recognized for testing and calibration laboratories. Holding an ISO 17025 accreditation offers assurance that a laboratory meets the requirements for competence, impartiality, and consistency, ensuring accurate and reliable testing results. NSF recognizes that laboratories that do not hold ISO 17025 accreditation may also be accurate and reliable testing sites, however, it is beyond the scope of this program to take measures to verify and qualify laboratory activities. Results used to demonstrate compliance with Amazon's dietary supplement policy are to be generated by a laboratory that holds accreditation to ISO 17025.

Q: Why does the scope of the ISO 17025 certificate matter?

A: The scope of the ISO 17025 certificate details the methods that a laboratory has demonstrated competency, reliability, and accuracy. The scope details the accredited test method, relevant regulation or standard, and any limitations or exclusions (such as limits of detection or specific matrixes). An ISO 17025-accredited laboratory may perform methods for which they are accredited, as well as methods for which they are not accredited. A method included in the scope of the accreditation (or accredited method) has been evaluated to the ISO standard, while other methods have not been. NSF recognizes that methods that are not included on an ISO 17025 accredited scope may also be accurate and reliable, however, it is beyond the scope of this program to take measures to verify and evaluate methods.

Q: What information will a lab be asked to share if data is accepted?

A: If data is accepted by NSF, the third-party laboratory that generated the COA/report will be contacted directly by our technical review team. The laboratory will be asked to verify the authenticity of the COA/report and reported results. This ensures a COA/report was not altered or modified and represents the results as reported from the third-party laboratory.

Q: Does NSF copy methods from other labs to confirm results?

A: No. Method development and evaluation are beyond the scope of the program. NSF will not request methods from labs or attempt to qualify/perform proprietary or novel methods.

Q: Does NSF accept data from proprietary or novel methods?

A: No. The evaluation of proprietary or novel methods and method validation is beyond the scope of the program. NSF will not request methods from labs or attempt to qualify/perform proprietary or novel methods.

Q: Can I request NSF use a proprietary or novel method to confirm my data if I share the method?

A: No. The development of proprietary or novel methods and method validation is beyond the scope of the program. NSF will not attempt to qualify or perform proprietary or novel methods.

Q: What happens if NSF doesn’t have a standard to confirm the identity of one of my botanical ingredients?

A: Standards and/or standardized methods are not available for all botanicals. If a scientifically valid method is not available to evaluate a particular ingredient it is considered “untestable” and does not contribute positively or negatively to the assessment of the product’s ability to meet the Amazon compliance standards.

Q: What happens if there isn't an established testing method for a particular substance?

A: The development of proprietary or novel methods and method validation is beyond the scope of the program. If a scientifically valid method is not available to evaluate a particular ingredient it is considered “untestable” and does not contribute positively or negatively to the assessment of the product’s ability to meet the Amazon compliance standards.

Q: What do “inconclusive” results mean?

A: The result “inconclusive” is generally seen regarding qualitative evaluations. That means the laboratory was trying to determine if the compound in question was present at detectable levels in the sample. “Inconclusive” means that the evaluation could not confirm whether the compound was present. Inconclusive may mean the method is not suitable for the particular sample.

Q: What does “does not conform” mean?

A: The result “does not conform” is generally seen regarding qualitative evaluations. That means the laboratory was trying to determine if the compound in question was present at detectable levels in the sample. “Does not conform” means that the compound in question was not identified as present in the sample.

Q: Is the NSF laboratory ISO 17025 accredited?

A: Yes. NSF’s laboratory is audited by both the International Accreditation Service and the Standards Council of Canada for a large variety of methods.

Q: Is the NSF laboratory audited by an independent third party?

A: NSF’s laboratory is audited by both the International Accreditation Service and the Standards Council of Canada in support of the ISO 17025 scopes.

Q: Does NSF subcontract to other laboratories?

A: While NSF’s laboratory houses a wide range of testing, occasionally tests are sent to other laboratories that hold expertise in certain areas. NSF first ensures that the proposed subcontract lab has the technical capabilities and experience required for the sample type NSF would be subcontracting. Additionally, NSF verifies that the lab uses scientifically valid and fit-for-purpose methodologies. There is a scope for how the outsourced lab is to be utilized, with only certain tests going to any lab. The quality assurance team at NSF reviews the labs’ standing with ISO 17025 and may include an audit to determine if the principles and practices of ISO 17025 are being met by the lab.

Q: Who should a lab contact for inquiries?

A: Please contact AmazonSupport@nsf.org and they can help further direct your inquiries if needed.

Q: I already have an NSF GMP certification, does that satisfy any of the requirements?

A: Yes! If this certificate is current and in good standing it satisfies the GMP Amazon compliance requirements.

Q: I already have a GRMA GMP certification, does that satisfy any of the requirements?

A: Yes! If this certificate is current and in good standing it satisfies the GMP Amazon compliance requirements.

Q: I already have an NSF-certified product, does that satisfy any of the requirements?

A: Yes! If this certificate is current and in good standing it satisfies the Amazon Dietary Supplement program requirements. When you initially contact NSF for your Amazon compliance let us know you already hold a product certification.

Get started on your compliance journey by speaking to NSF today.

• Call: +1 313 456 8832, Monday – Friday, 7:30 am to 8:30 pm EST.
• Email: amazonsupport@nsf.org
• Visit Seller Central and select NSF as your testing partner.