This is a guest blog post by Carol Harvey, Director of food/nutrition labeling and product development at Palate Works.
One of the latest concepts in “enhanced hydration” is to “deploy” supplements into bottled water at the time of consumption, rather than let them soak for months and potentially lose potency.
At least two companies have products that do this via a nutrient delivery system where you twist or push in the bottle cap to release a spoonful of vitamins and other ingredients.
Karma Wellness Water is one of these. The instructions are to “peel… push… shake to initiate the health benefits…[and] transform water into wellness.” Each flavor has a different theme: Balance, Vitality, Body, Spirit and Mind.
Interesting concept, but there are at least two costs: monetary and taste. Wouldn’t it be cheaper (than the $3 per bottle) and just as convenient to pop a vitamin/supplement pill with plain water or tea? As for taste, if you aren’t expecting the “water” to be noticeably sweetened with soapy/chemical-tasting stevia along with some sugar, there could be shock at first sip, and not much taste enjoyment afterwards.
While the company should be commended for pointing out that certain vitamins can be lost via exposure to UV light, heat, air, etc. (although whether this happens to a significant extent in pre-enriched beverages isn’t addressed/documented), there are many issues with the product and its marketing that deserve counter Balance:
The web site FAQs give only non-scientific resources/links to back up the albeit generally-true vitamin-deterioration claims, and these mostly address the potency loss from vitamins in pill form. A CNN blog cited doesn’t discuss any potency problem, but rather toxicity (too much supplementation), in vitamin waters. It also says that fat-soluble vitamins won’t be absorbed unless eaten with fat-containing foods – partially true, but not even mentioned by the Karma people, whose products all contain fat-soluble vitamins but no fat. Furthermore, the CNN expert doesn’t recommend getting your nutrients from supplemented water in any case. Then there’s the issue of high doses of water-soluble vitamins such as the 1000mg of vitamin C in the Balance formula being mostly sent to the toilet. Keep in Mind that the Karmics have two MDs and a PhD in nutrition on their advisory team.
Something else the advisors don’t do (besides following the links from their web site) is research the Body of food labeling regulations.
FDA considers water to be a food, not a supplement, even when it contains supplements. If you drink the product like a beverage (and if it’s called “water” and comes in a bottle… it is a beverage), it should be labeled as a food/beverage product with a Nutrition Facts label, not a Supplement Facts label. And it needs a proper ingredients list.
In the further Spirit of enlightenment…
- Caffeine is listed when it comes from green tea, but the stimulant status of herbs such as yerba mate are not. Yet they say the product is “absolutely” safe for kids. Can we see a link/resource backing that up? While not required, it’s best to indicate which ingredients are stimulants (and how strong), as they can have serious health (and PR) effects.
- All the bottles state “low calorie.” Assuming a bottle of water could be called a supplement, it would not be permitted to use a low calorie claim:
A “low calorie” claim may not be made on dietary supplements, except when an equivalent amount of a dietary supplement that the labeled dietary supplement resembles and for which it substitutes … normally exceeds the definition for “low calorie.” 21 CFR 101.60(c)(1)(iii)(A)
Basically, if something isn’t normally high in calories (e.g., vitamin pills or water), then there shouldn’t be a claim about it being low in calories.
The Vitality of marketing-speak runneth over on these products, but there are fixes to Boost their taste and their Immunity to FDA warning letters:
1. Change the Supplement Facts to Nutrition Facts.
2. Make the nutrition/ingredients panel bigger/legible (the bottle qualifies as a regular size, not small or intermediate, so the type should be larger). The main text should be no smaller than 8 pt.
3. Take out the stevia. It gives a diet Kool-Aid, overly faux-sweetened taste. A small amount of sugar and fruit essence, and/or a dash of real fruit juice is a better choice for a “wellness” product and calories can still be low.
4. Indicate on the main label that the fruitiness is “from natural flavors” (as required) so people won’t think the beverage contains real fruit… or add some real juice from those fruits depicted on the bottle.
5. Remove “Fresh” in reference to the vitamins (that term is not allowed here per 21CFR101.95).
6. “Proprietary Blend” is listed on the Supplement Facts label, but the blend components are not indented below, so it isn’t clear if they are part of the blend. If they aren’t, then the blend ingredients aren’t being declared, which is not allowed. Most likely, this is a formatting error – use indentation. (See Supplement Facts photo above.)
7. Remove claims from package, web site and marketing materials (all are considered “labeling”) that imply a drug-like benefit, such as “stimulates focus,” “immunity booster” and “anti-aging.”
8. If using health claims, make sure they are allowed ones, or (for structure/function claims on true “dietary supplements”) the required disclaimer is displayed.
So, why do these details matter? It’s all about not misleading consumers (or otherwise preventing them from comparing products on a level playing field), or having an unfair competitive advantage vs. products that do follow the rules.
Please label drinks responsibly.
Carol Harvey has been a nutrition labeling and product development consultant for over 15 years. She can be reached at palatemail [AT] yahoo [DOT] com.