A much-touted recent investigation by the New York State Attorney general’s office claimed national store brand herbal supplements sold at GNC, Target, Walgreens and Walmart in fact did not contain the herbs shown on their labels. Instead they found such things as mustard, wheat, radish and other substances.  All four stores were given cease-and-desist letters demanding that they stop selling a number of these supplements.

It was claimed that few of the products investigated were found to contain the herbs on the labels and many may have contained potential allergens that were not identified on the list.

According to the New York Times, the letters stated that “contamination, substitution and falsely labeling herbal products constitute deceptive business practices and, more importantly, present considerable health risks for consumers.”

The American Botanical Council (ABC) quickly issued a rejoinder to the action of the NY AG in a press release “ABC Says New York Attorney General Misused DNA Testing for Herbal Supplements, Should Also Have Used Other Test Methods as Controls.”

As an herbalist I’m well aware that there is and historically has always been a problem of contamination and adulteration of herbs. I’m all for the Attorney General of New York or any other regulatory agency serving as a watchdog and enforcement agency for such matters. I do not hold any great sympathy for the companies that were investigated and found at fault. When it comes to herbs, I’m more in favor of customers purchasing from reputable manufacturers whose specialty is manufacturing and marketing herbal products. Ideally it would be reasonable and much better if such companies had actual herbalists as part of their staff.

The problem with this overzealous and misguided investigation is that the only method for testing they used is a process called DNA barcoding, which identifies individual ingredients through a kind of “genetic fingerprinting.” “DNA” has a ring to it that is particularly appropriate if a prosecuting attorney is seeking the conviction of a serial rapist or sociopath but unfortunately when applied to herbal identification as a ‘stand alone’ method, it is widely regarded in scientific pharmacognosy as unreliable. It’s not clear whether whole herb products were tested, or herbal extracts. It is well known in the industry that DNA testing is not reliable for extracts or preparations involving heat that leave little genetic material intact after processing.

Leading pharmacognocists have pointed out this problem and the obvious absence of controls involved with the procedure. It could have only been ignorance on the part of the New York attorney general Eric T. Schneiderman and his staff, that before publicly condemning these outlets and their products and issuing ‘cease and desist’ orders that industry testing standards be applied. These would be HPLC (high performance liquid chromatography), HTLC (high performance thin layer chromatography) or infrared spectroscopy.

Unfortunately this makes it look more like another smear at an industry that someone doesn’t like rather than a sincere effort at regulation.

The American Botanical Council, an independent organization that along with the herbal industry generally is sympathetic with the Attorney General’s concern regarding deception and adulteration of dietary herbal supplements, takes issue with the obvious oversight regarding more sophisticated methods of testing and evaluating herbs that are available.

The investigators tested 24 products, each claiming to be seven different herbs, echinacea, garlic, ginkgo, ginseng, saw palmetto, St. John’s wort, and valerian. According to the press release, only 21% of the store-brand herbal supplements contained DNA from the plants listed on the products’ labels, with Walmart’s products containing no DNA from a botanical source.

Checking the labels of Walmart’s herbal products, all except echinacea are described as standardized extracts. This only should be cause for any credible investigative agency to employ testing methods other than DNA genetic barcode testing. Wouldn’t it be ironic if instead of being the lowest potency, because they are all standardized extracts they turn out to have the highest potency compared to their rivals, GNC, Target and Walgreens?

Other problems with this sensationalistic smear against the herbal industry which has now wormed its way through myriad media outlets and the Internet is that the individual the Attorney contacted to conduct the DNA genetic barcode study was Prof. James A. Schulte II PhD, of Clarkson University in Potsdam, New York. Dr. Schulte’s background is in evolutionary biology and reptilian zoology and is not recognized as an expert in botany, pharmacognosy, or natural product chemistry.

Another fact for critical relevancy is that the highly respected University of Mississippi’s National Center for Natural Product research issued the following statement:

“The AG’s test results do not comport with other recently published research on herbal dietary supplements. Two recent tests from reputable laboratories on commercial ginkgo extracts have found ginkgo in all or almost all of the samples tested.”

Herbalists welcome fair and unbiased regulations for its industry. I know herbs are not regulated as drugs but as foods or food supplements, but even at that level, the fact that some unscrupulous entrepreneurs decided to exploit ma huang (Ephedra sinica) for instance, as a type of speed for weight loss and recreational use, got shut down. However the upshot of all of this is that one of the most valuable herbs for upper respiratory problems including asthma, emphysema and respiratory allergies is banned from the market place.

Herbalists generally and certainly herbalists who own herb manufacturing companies make a point of promoting quality in the market place. As to the company I have been associated with, Planetary Herbals, the levels of testing and accountability that even a single product must undergo before it is placed on the market is exhaustive to say the least.

The public who relies on herbs and natural supplements for their health needs as well as those of us who involved in the various aspects of producing and marketing them, all have a stake in reasonable, high quality industry standards. While it’s questionable that those seeking herbal supplements would look to purchase the at stores such as Walmart, Walgreens and Target, I’m just happy that they are available to the mass market and if people are looking for higher quality brand names, they should seek out specialty herb stores, herbalists and natural food stores. Nevertheless there are several quality manufacturers who produce decent quality herb products for private labeling.

Speaking with Nutra Ingredients USA, Dr. Pieter Cohen of Harvard, an outspoken critic of the industry, is quoted as saying “If you’d said 10% of the products couldn’t be identified, then I’d have believed that, but 80%? That’s unbelievable.” GNC, a generally high quality national distributor of natural supplements and one least likely to be selling bogus herb products, has taken to using Dr. Cohen’s even while agreeing to comply with the AG’s letter.

Ed Smith, herbalist and founder of Herb Pharm, one of the country’s largest herbal supplements manufacturers, recently stated, “I feel we should definitely condemn the NY AG’s very flawed ‘expose´.’ If he gets away with this then he and/or others will do similar sloppy and misleading work again. We should hold them to the same high level of professionalism that they demand of us.”

With the herb industry reaching an estimated 5.3 billion dollars in 2011 (according to Mark Blumenthal), unlike previous legal battles with regulatory agencies, the industry is showing signs of maturity welcoming appropriate regulatory actions for the good of all but criticizing what in this instance appears to be poor methodology on the part of New York attorney general.

(Added 2/11/15) In the most recent response to the New York attorney general’s cease and desist order GNC, a reputable supplements manufacturer and distributor has rebutted the AG’s accusations: 

GNC: Tests and re-tests show that ‘products contain the ingredients stated on the labels at the levels indicated on the labels’

By Stephen Daniells+, 10-Feb-2015

GNC Holdings has responded to the NY Attorney General’s actions with full and robust responses to every question raised in the cease and desist letter, including original test results and the results of retesting that was performed on the product lots cited in the letter.

herbbundles

Many people in the West eschew herbs from other countries because they only want to use western herbs. While local herbs are the easiest and most convenient choice, they’re not necessarily the best and even more so, not always possible. Even if you’re an avid gardener who cultivates a large variety of herbs, you still won’t have all you may want, if for no other reason than your local ecosystem limits what’s available to you.

Further, the herbs you need might not even grow in the West (or at least haven’t been discovered or harvested yet). That means most people at some point will have to buy the herbs they need. You probably look for organic herbs, like I do, but not every western herb may be found in organic form. And an herb is not necessarily non-organic just because it’s from another country.

Ultimately, the question all this raises in me is, what makes an herb "western?" Because it‘s native to the West? Grows in the West? Is commercialized and so known to the West? Or was used by old-time western herbalists? And how do we define a "western" herb, especially since our western herbal borders have spread to include adaptogens from eastern Russia, tonics from South America, and resins from the Middle East?

When it comes to sourcing herbs from faraway places, perhaps the problem many people specifically have is around herbs bought from China and India. Most people’s concerns about these herbs revolve around their cleanliness. Certainly pollution is growing in China and India, compounding their past use of adulterants, coloring agents, and heavy metals. And yet, many western herbs are adulterated, too. 

Consider that many Chinese and Ayurvedic herbs are actually wildcrafted from high altitudes on mountains, volcanoes, or other remote areas. Further, many Ayurvedic formulas are extensively prepared with prayer and mantra and go through lengthy purification processes. Surely if the concern is purity, such herbs are adequate for western consumption?

Even if "impure" Chinese herbs are used, I’ve still seen them benefit people tremendously. I’ll never forget a patient I once treated in the late 1980s who had Crohn’s disease. She could only eat eight foods and yet she progressed well on irradiated Chinese herbs. This is probably because those herbs’ tonifying properties were stronger than any toxicity or devitalization they might have had. In this case, the disease was worse than the medicine being taken. Even impure herbs are still better to take than drugs loaded with their many side effects.

In the end, I don’t actually think pollution is the full problem behind people choosing to exclude Chinese or Ayurvedic herbs. Many plants from other countries are now readily incorporated into mainstream western use, such as ginseng, albizzia, astragalus, goji berries, reishi, ashwagandha, triphala, eleuthero, rhodiola, myrrh, and suma. These Chinese, Ayurvedic, East Russian, Middle Eastern, and South American herbs have been commercialized and so are now well received. Plus, there are good sources that provide reliable Chinese and Ayurvedic herbs today.

Further, and this may surprise you as it did me, most western herbs in the U.S. actually come from other countries! According to Roy Upton, executive director and editor of the American Herbal Pharmacopoeia® and director of Planetary Formulas, probably close to 90% in weight of herbs in the States come from elsewhere. His colleague, Josef Brinckmann, who routinely watches the international plant market, confirms that the overwhelming majority of herbs by volume used in the U.S. are imported form other countries.

Of the "big 10" U.S. sellers – cranberry, saw palmetto, soy, garlic, ginkgo, Echinacea, milk thistle, black cohosh, St. John’s Wort, and ginseng – only cranberry, saw palmetto, echinacea and black cohosh are native North American botanicals, and of these four, black cohosh extract is adulterated with Chinese material and the most widely used echinacea extract, or E. purpurea, is cultivated in Europe. This means that only two of the top selling herbs in the U.S. – cranberry and saw palmetto – are actually sourced from North America!

So what is the real problem behind shunning non-"western" herbs?

Could it be that people think they first need to learn a complicated system before using Chinese or Ayurvedic herbs? If this is the case, it’ s not actually so. One just needs to understand herbal energetics, and frankly, this is true for any herb chosen no matter what part of the world it comes from, East or West. It’s necessary to know an herb’s cooling or heating energy, flavors, direction, properties and actions according to a specific system in order to use it appropriately. This is how herbalism works. Thankfully, there are many books, teachers, and other resources available that easily provide such information.

In truth, many people don’t know that they’re already using Chinese and Ayurvedic herbs. Such herbs are valuable to all systems of herbal medicine. Licorice, mint, ginger, garlic, cardamom, and dandelion are all widely used in China and India along with dozens of other examples, though some are different species. Then there’s the opposite situation where our own unused American ginseng tonic is bought by the Chinese and then sold back to us. The Chinese don’t shun this herb because it doesn’t come from China; rather, they see it as an important plant that is irreplaceable in their pharmacopeia.

Here is a list of herbs now common to Western, Chinese, and Ayurvedic herbalism:

Ginger, garlic, scallions, horny goat weed, asafetida, aloe gel, angelica, barberry, black pepper, calamus, aster, cinnamon, fenugreek, gentian, hibiscus, juniper, gotu kola, mugwort, myrrh, mint, rose, rhubarb, turmeric, valerian, horsetail, kudzu root, black cohosh, self heal, figwort, honeysuckle, isatis, violet, andrographis, anemone, mung beans, sweet Annie, malva, plantain, aduki beans, corn silk, loquat, jack-in-the-pulpit, hawthorn, citrus peel, cattail pollen, agrimony, madder root, galangal, frankincense, motherwort, safflower, ginkgo, albizzia.

When I think about desiring only local herbs, I think of ease, convenience, and knowing what I am getting. I understand such desires. It is still much easier to obtain "western" herbs than Chinese and Ayurvedic plants. Also, Chinese herbs are becoming quite expensive. With the growing free enterprise in China, prices have at least doubled or even quadrupled in some cases, particularly with patent medicines. Other herbs are being illegally hoarded, making them unavailable.

And yet, what if what you need isn’t available locally or as a western herb? Then what do you do?

First, know your sources. Look for Chinese dao di herbs that come from their authentic natural locations in remote mountains or other wild spaces where they’ve been cultivated, harvested, and processed since the Tong Dynasty (618-907 C.E.) with certain techniques to yield superior effects. These herbs have different constituents because of their interaction between a specific natural location and their genetics. Such herbs have an enduring reputation for high quality and excellent treatment effects. They are not polluted and some herb companies specialize in obtaining and selling them. This is like saying the best feta cheese comes from Greece, and the best Gruyere comes from Gruyere, or that Napa wine is better than Nebraska wine.

Along with such geo-specific and geo-authentic plants, it’s also important to purchase herbs from companies that test their products for authenticity, potency, and purity (this should ideally be the practice of all western herb companies) as well as follow GMPs (Good Manufacturing Practices, the standards set for safe products).

Next, realize that your health and healing requirements may not fully be met if you only use western herbs. The plants you need may not grow in your local ecosystem or even be available in the West. For example, true tonics are restoratives and adaptogens and most of these come from the eastern mountains of Russia or from South America, China and India. The idea of "tonics" in western herbalism is quite different than that in Chinese and Ayurvedic medicines. What Western herbalists believe is tonifying, such as a bitter tonic or blood tonic, is either a detoxifier, a stimulant to organ function, or provides needed minerals.

For example, western blood "tonics" are bitter and cooling in nature, like yellow dock. However, blood itself is warm and moist, the exact opposite of yellow dock’s energies. This means that bitter and cooling yellow dock, although high in iron, actually dries and depletes blood rather than builds it. However, if molasses is combined with yellow dock, a warming and moistening medicinal also high in iron, the herb’s negative effects are neutralized and it then builds blood.

True tonics In Chinese medicine have a different definition and function. By nature, most tonics are sweet in flavor, which builds, slows, and harmonizes (this is a complex and not simple sugary sweet). Such tonics boost, benefit, help and/or repair. This is very different than the bitter flavor, which drains, dries, and makes firm.

Until we identify more tonic herbs in the West, we must continue to obtain them from other countries. This means using some non-western herbs if you are depleted and need to build and strengthen your body and health.

The bottom line in using Western versus Chinese or Ayurvedic herbs, however, is that no herb can really substitute for another. Even the same exact herb grown in different locations has unique properties not found when grown in another area. This is why many Chinese only use dao di herbs since they grow in optimal locations to stimulate the development of specific properties.

The pinch today is that some of the most effective Chinese herbs are no longer allowed or have limited availability to non-practitioners.  So what do we use instead?

The writing is on the wall and we are almost being forced into finding western substitutes as best we can for those lost valuable herbs. This need has long intrigued me and finally I am looking at it in depth. Yet, it is a complicated study that involves many factors. These I will begin to address in my next blog!

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