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Worrying prospect!

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I have been examining the detail of the 'Traditional European Herbal

Directive' and how it affects production of tinctures, tablets, capsules

etc.

The biggest problem for suppliers of OTC tinctures etc is that all products

have to be quality and stability tested. This means, in short, that all

herbal products have to justify the shelf-life applied to them by

manufacturers, suppliers etc. This means that 'fingerprints' of active

constituents have to remain within 5-10% of the starting point through the

life of the product (it also means microbiological and heavy metal type

testing etc...all costing thousands) . Most companies would be looking for a

2 year shelf-life.

As herbalists, we already know that tinctures and liquids are far more

unstable than solid extracts. Interestingly, and worryingly, tinctures

already subjected to testing do not appear to make the grade. So what is

happening now is that companies are dropping liquid extracts in favour of

solids in tablets and capsules. This trend means that post 2011 companies

with registered/licensed products for OTC sale to the public will be selling

tablets or capsules. This will leave us with the interesting position of

companies using 'high quality, tested, legal, registered products', and

herbalists using unregistered, and as far as the 'authorities (MHRA)' are

concerned, poor quality and untested tinctures. We are then one step away

from the MHRA advising that the public not use unregistered, untested

products, which is only a short step away from a ban. Fuel (i.e. cash and

publicity) for such a ban could come from the MHRA's own publicity machine

and herbal companies post 2011 with vested interests in products that took

thousands of pounds to register.

Is anyone as scared as I am? What are all you tincture makers doing? Any

thoughts?

Stuart Fitz

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