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WELCOME to theFACTORY-DIRECT GLOBAL SOURCING EVENT
SO CAL ROADSHOWFEATURED FACTORY SPONSOR: BBFY
A B2B E-COMMERCE PLATFORMCONNECTING BUYERS AND SELLERS WITH NUTRITIONAL INGREDIENTS
I N T RO D U C T I O N
I N T R O D U C T I O N
DAVID JIExecutive Vice PresidentBusiness Development
EXECUTIVE TEAM
SHERRY WANGFounder and President
PEGGY JACKSONVice President Sales/Marketing
I N T R O D U C T I O N
FACTORY-DIRECT
FACTORY-DIRECT ONLINEB2B E-COMMERCE MARKETPLACE
FACTORY CUSTOMER
I N T R O D U C T I O N
SERVING FIVE INDUSTRIES
• DIETARY SUPPLEMENT
• FOOD & BEVERAGE
• COSMETIC
• ANIMAL NUTRITION
• PHARMACEUTICAL
I N T R O D U C T I O N
CURRENT DATA
• 5,000+ Registered Members• 74% Reorder Rate• 1,000+ Ingredients• 200+ Factories• 180+ New Registrations Per Month• 145,000+ Page Views Per Month
I N T R O D U C T I O N
TOP INGREDIENT SALES BY VOLUME
• ASCORBIC ACID
• BCAA
• CITRIC ACID
• CoQ10
• CREATINE MONOHYDRATE
I N T R O D U C T I O N
TOP INGREDIENT SALES (CONTINUED)
• L-CITRULLINE
• L-GLUTAMINE
• STEVIA
• SUCRALOSE
• TAURINE
I N T R O D U C T I O N
FACTORY PARTNERS IN THESE COUNTRIES
• CANADA
• CHINA
• FRANCE
• GERMANY
• INDIA
• INDONESIA
• ITALY
PAKISTAN •
ROMANIA •
SOUTH KOREA •
THAILAND •
UNITED STATES •
I N T R O D U C T I O N
FACTORY TRANSPARENCY
We encourage everyone to meet our factory partners
• Executive level meetings at customer facility offering technical support and exchange
• Arrange customer visits to audit our factory partners
• Arrange for meetings at various events throughout the year
Please view our video presentation here:https://www.youtube.com/watch?v=G60KScOaYiQ
I N T R O D U C T I O N
WHY INGREDIENTSONLINE.COM?
Size of U.S. Supplement Market• $41 billion U.S. supplement industry by product category
(vitamins, minerals, herbs, etc.)
• $196 billion U.S. nutrition industry by channel (natural & specialty, mass market, multi-level, etc.)
Source – Nutrition Business Journal – Supplement Industry Report, 2017
I N T R O D U C T I O N
RESOURCE SAVINGS WITH INGREDIENTSONLINE.COM
Save Time, Save Money with Radical Transparency- Eliminate Broker/Distributor Added Costs
• 798+ ingredient brokers/distributors
• According to Datamyne, less than 10% of those directly import
• $40B in U.S. supplement sales at a estimated rate of 25% in raw material costs or $10 billion
I N T R O D U C T I O N
RESOURCE SAVINGS WITH INGREDIENTSONLINE.COM
• With brokers/distributors taking 10% to 15% margins, that is conservatively $1 billion to $1.5 billion in added costs
• These savings are calculated for the U.S. supplement industry only
I N T R O D U C T I O N
RESOURCE SAVINGS WITH INGREDIENTSONLINE.COM
• The savings for all those categories is billions and billions of dollars.
• No waiting on middlemen for documents or products. Order factory-direct online instantly, 24/7!
S P E A K E R S
FEATURED SPEAKER
Jim Lassiter oversees all consulting divisions at Ingredient Identity, leveraging over 40 years of experience in quality control and regulatory & government affairs in the
pharmaceutical, food, dietary supplement and cosmetic industries for companies and organizations such as Nutrilite (Amway Corp), Robinson Pharma, Irwin Naturals,
Chromadex, AHPA and CRN. He served on numerous industry and trade boards and is a contributing author to several online and print media forums.
His work has received notable recognition in trade publications and journals including
the Food and Drug Law Institute Update, Natural Products Insider, The Tan Sheet and FDA Weekly. A recognized and respected voice of the industry, Jim frequently offers his
insight at various discussion forums, webinars, conferences and panels of industry renowned experts. Jim holds a M.Sc. in Biochemistry from Berkeley and an M.B.A. from
Pepperdine.
Jim Lassiter
Chief Operating OfficerIngredient Identity
Founder - Jim Lassiter, M.Sc. MBA©2018 INGREDIENT IDENTITY
GUIDANCE � DEVELOPMENT � COMPLIANCE©
Do You Suffer from RD*?
*Regulatory Dysfunction
Objectives
Understand the Law and Regulatory Structure
Understand the Roles of FDA and FTC
Understand the Challenges RD Creates
Labeling and Claims
Manufacture, Packaging and Distribution
Know the Basics to identify the Need
Learn where the current regulatory ”squeaky wheels” are
Identify upcoming regulatory challenge
Determine what you can do
Identify what to emphasize going forward
©2018 INGREDIENT IDENTITY
The Basics
Congress Passes LawsFFDCA: 1938Rogers/Proxmire Amendment: 1976NLEA: 1990DSHEA: 1994FALCPA: 2004FSMA: 2011
Regulatory Agencies Interpret the LawRegulationsGuidance DocumentsAdditional Pronouncements
Regulations and Actions Carry the Force of The Law
©2018 INGREDIENT IDENTITY
21CFR §101.93 – Structure/Function Claims Requirements
FTC Guidance Regarding Promotion of Dietary Supplement Products
Discussions and Notations from FDA on various topicsInflammation
Social Media
Regulatory actions against companies
Critical Regulatory Items
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
There are NO regulations telling you specifically what NOT to say
There are classes of claims other than structure/function and therein lies the challenge
Interpretation is the key and the cause
The audience is IMMATERIAL
Additional Regulatory Items
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
Avoid Drug ClaimsThe five Magic Words
Avoid Specific AreasCholesterolBlood SugarInflammationChelation
Watch Out for Every Changing Hot Button ItemsWeight LossSexual EnhancementInflammationCardiovascular Claims (delicately handled)
Know the Difference in ModifiersPromotesSupportsHelps Maintain
Some Critical Elements
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
Regulatory Caveat: It DependsQuality of the ScienceApplicability of the ScienceAdequacy of the Science
Key Words that May be UsedImproves [rarely]Promotes . . . . Benefits from . . . .Helps with . . .Supports . . . .
What Can YOU Say
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
Regulatory Caveat: It DependsLabelLiteratureElectronic LiteratureTraining SessionsSocial Media
Each has its own pitfalls and opportunities
Where Can You Say It
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
FDA Discovers FacebookKey Elements:
Is it YOUR page?Is the Testimonial “liked”?Is the Testimonial from and Expert?Is the Testimonial “over the line”?
Clean Up the Act RoutinelyBlogs, Private Pages, Password Only Access
No safe harborIntent is NOT sufficientWatch the link-outs as well
The Social Media Challenge
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
Everything PrintedPaper or Electronic
Everything SaidTraining SessionsHandoutsSponsored Presenters
Expert TestimonialsGenerally FTC governanceBased on Clinical ExperienceWatch the Corporate Relationships
Say Again?
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
Just because it’s truthful doesn’t mean you can say itFree Speech vs. Controlled Speech
Science Can Pose ChallengesSubstantiation using HEALTHY populationsDeclaratives out of one studyDifference between an ingredient and a productKnow the Quality of the studies
TestimonialsDocumented Mechanism of Action
Science and Controlled Speech
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
GMPs are 11 Years OldFDA is Probing More In DepthExpectations are higher
Requirements for ManufacturersDocumentationTesting
These are NOT the Only Folks with RDOwn Label DistributorsAnyone who does anything with the product
The Production
©2018 INGREDIENT IDENTITY
Simple ThingsMMRs and BPRs
Requirements and detailsComponent Specifications
Details in dysfunctional statesFinished Goods Specifications
Details in What is TestedDysfunctional Approaches
Greater DetailMethodsReferencesDysfunctional application of technology
Fundamentals
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
The expectations are more detailedYield CalculationsExemption from TestingSignatures in placeDates AND times of activitiesDetails of the steps performed
The expectations are NOT newDiscretion to dateDysfunctional to date?
Details
©2018 INGREDIENT IDENTITY
Seems SimpleSimple dysfunctionRequired to know the performane of their contractors
Audit of contractorsBatch RecordsShared Responsibility
Quality OperationsDo you distribute?What do you need to be functional?
Own Label Distributors
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
ScienceSubstantiation of claimsTesting of the componentsTesting of the finished goodsSupport for the testing chosen
Instructional DetailsThe “how to” portion of your functions and activities
What is Functioning Next?
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
HistoryThe way we’ve always done it
Uneven enforcementNot even noticed within the operationThere is no Little Blue Pill
Causes of Dysfunction
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
What We’ve Always DoneCertificates of AnalysisSkip Lot TestingTesting Only a Little
What We Don’t DoGather SubstantiationDocument our Functional CuresTest Appropriately
There are some allowancesSTOP relying on FTIR or NIR
Historic Challenge
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
They Said it – Why Can’t We?Wait your turn – and theirsHow much do you want to risk?How much do you want to spend?
If THEY said it What Can You Do?NADFTCFDA
Know the ramifications of the attackKnow that turn-about is fair playKnow that “justice” is slow
The Dysfunction of Uneven Enforcement
©2018 INGREDIENT IDENTITY
Production RecordsMMRs and BPRsAll Elements and Requirements
Testing MethodsAppropriate
Current USP Is 41Suitability to Purpose
Contract Lab EvaluationANY OOS activities
Material ReviewInvestigationsDocumentation
The Documentation of Function
©2018 INGREDIENT IDENTITY
Determine to FunctionRisk aversion – How Much Do You Want?Learn to know where the trip wires areEvaluate Each documentLeave History behindKeep an attorney on speed dial – not necessarily on retainer
The Company Determination
©2017 INGREDIENT IDENTITY©2018 INGREDIENT IDENTITY
The Current AdministrationNOT an acceptance of dysfunctionDoes NOT control the enforcersDetailed evaluation of existing regulationsYes, delay has occurred but . . .Administrations ChangeThere is NO effort to roll back regulations
Administrative Relief
©2018 INGREDIENT IDENTITY
RD is a Serious IssueAcceptable:
Details in the processMeeting All of the Obligations
DocumentationSubstantiationMethod Performance
Unacceptable:Coming Up Short on DocumentationComing Up Short on ImplementationComing Up Short on Compliance
What Is Your Dysfunction?
©2018 INGREDIENT IDENTITY
Initial StepsAdmit you have the problem
It’s nothing to be embarrassed aboutIt’s totally fixable
Commit to ComplianceBe RationalBe Efficient
Identify the Gaps
Treatment of RD
©2018 INGREDIENT IDENTITY
ActionsBe reasonableBe circumspectImplement a Plan
RecognizeProgressTraining NeedsProcess not a Project
Dealing with RD
©2017 INGREDIENT IDENTITY
RD is not uncommonHistoric causes“Nature of the Industry” causes
RD can lead to more serious challengeFDA is digging deeperExpectations are higher and actions more severe
RD is very treatablePlan, Commit, Implement, RepeatSeek professional help – but not reliance
Summary
©2018 INGREDIENT IDENTITY
Who We Are - BBFY Industrial USA
• Subsidiary coporation of BBCA Group in China
• Started business in America in 2010
• Specialized in the ingredient of food/feed industry
• 20,000 square feet warehouse both in CA and NJ
• Biggest player in U.S market of Citric Acid and D-aspartic acid
• Total revenue in 2017 is 40 million USD
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What We Can DoProducts:
• Citric Acid• D-Aspartic Acid• L-Alanine• DL-Malic Acid• Biotin Pure• L-Ascorbate-2-Phsophate
Service:• Prompt shipping, standard documents, quick response to the clients.
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BBCA/BBFY and ingredientsonline.com™
• Partnership in the very beginning of the online platform was built
• BBFY became one of ingredientsonline.com’s™ golden members
• Strong support for each other
• Both of us are optimistic about the development of this online platform
in the raw materials industry in the United States
����������������� ����������� �������
BBCA Group is a Major Bio-chemical Technology and Innovative Multinational Enterprise.
Revenue in 2017: 1.5 Billion USDTotal Employee: 11,000
1958
Bengbu Chemical
Plant
Bengbu Citric Acid
Plant
(3000MTs/year)
New patent of citric acid fermentation
technology (6000MTs/year, the third
largest in China)
1. BBCA Group founded
2. BBCA Biochemical founded
and listed (60,000MTs/year
of citric acid ,the largest in
China )
BBCA Pharmaceutical founded and listed
APIs:
1. Analgesics-antipyretic drugs
2. Anti-inflammatory
3. Cardiovascular
4. Anti-biotics
5. Anticancer drug
1. 220,000MTs/year of citric acid the
largest in the World
2. 100,000MTs/year of lysine
3. 300000MTs/year of fuel ethanol
4. 100,000MTs/year of MSG
Total corn consumption: 3million tons per
year
BBCA History
19951995
1977
2000
2003
2006
1999
2006BBCA Biochemical was sold to COFCO
2009
2015
Second business design completed.Plants were relocated to BBCA Industrial Park which is 50KMs from the center of Bengbu City. 17 projects will be started in the Industrial Park.
2018
BBCA Group was reformed(state-owned shares were reduced from100% to 30%)
Thailand Citric Acid Plant (80,000MTs/year)
����������������� ����������� �������BBCA History
First Stage:• Plan to implement a total of 17
projects and 5 billion RMB investment
Progress:• By the end of 2017, 10
projects and about 3.38 billion RMB investment has been completed
• The rest of the projects will be done by the end of 2018
• Total Revenue: 4.5 Billion USD
Second Stage: • The local government has
stimulation plan and provides strong support in line with BBCA PLA product development
• Total revenue: 5 Billion USD
Industrial Develop plan
����������������� ����������� �������
Five Core Boards
BBCA biological• Lysine • Threonine• Alanine
BBCA biological• L- lactic acid• Malic acid
Tiger Biotech• VC derivatives• B vitamins
BBCA Biomaterial• Injection grade PLA• Fiber grade PLA• Film blowing PLA
BBCA Pharmaceutical• Pharmaceutical• Antipyretic-analgesia• Cardiovascular• Anticancer• Antibiotics• Antivirus
Industrial chain amino acid, organic acid company
ProfessionalVitaminManufacturer
Bio-based new material leader
Top 50 listed Chinese pharmaceutical companies
����������������� ����������� �������
► Citric acid and citrates► Lactic acid► DL-Malic acid► L-Malic acid► Fumaric acid
Organic Acid► Lysine► Threonine► L-Alanine► D-aspartic acid► L-aspartic acid
Amino Acid
► VC and its derivatives► Biotin► Folic acid► VB5► VB6
Vitamins
Products
► Corn starch► Crystal glucose► Crystal Fructose► Malt dextrin► Sorbitol
Starch and Starch Sugar
► Gelatin► Acetaminophen► Aspirin-dl-lysine► Triethyl citrate► Cilnidipine► Naftopidil► Lysine hydrochloride► Fructose► Glucosamine
APIs and Intermediates
����������������� ����������� �������
NORTH AMERICA BBFY Indutrial USA Inc.
BBCA AMERICA
►BBFY in CaliforniaStarted in 2010, 50 miles from the Los Angeles-Long Beach harbor.
►BBFY in New Jersey.Registered in 2013, 30 miles from the port.
����������������� ����������� �������
Corn Glucose Lactic acid PLA
The Process of new bio-material — PLA
Green fiber - the main alternative to chemical fibers in the future (PET, PBT, PTT, etc.) - Cloth
Green plastics - the main alternative to petrochemical plastics in the future (PeEEEEEEEEEEEE, PP, PVC, etc.).- Cups and plates.
Bio-fermentationtechnology Extraction, purification and polymerization
PLA
Saccharity
����������������� ����������� �������
CORN Lac Acid PLA
Green fiber
Green Plastics
AdvantageEnvironmental protection Anti-flaming Skin-friendly Anti-miteBreathability AntibacterialNon-moisture regain
Application of Poly Lactic Acid PLA����������������� ����������� �������
S P E A K E R S
FEATURED SPEAKER
Felicia Ly is the QA/QC Manager at ingredientsonline.com™ and one of the most integral parts of the team. With her wealth of product and regulatory knowledge, Felicia is responsible for all aspects of quality, manufacturer/product qualification, and internal and external regulatory compliance. Previously, Felicia has worked at Paragon Laboratories as their QC Microbiologist in addition to establishing their vendor qualification program. Felicia has also held a position at Organic by Nature, Inc. as their QA/QC Manager.
With her Bachelor of Science degree in Microbiology, Immunology and Molecular Genetics from UCLA, Felicia puts her skills to work ensuring products and their manufacturers meet and uphold the proper standards for quality and safety. Felicia can regularly be found at our major trade show booths to answer any and all of your questions regarding QA/QC at ingredientsonline.com™.
Felicia Ly
QA/QC
Q A / Q C
1. FACTORY QUALIFICATION
Factories must pass our Qualification Program before we bring them onto our platform.
PURPOSE: Ensure factory operations are compliant with GMP regulations and that the factory has the means to produce quality ingredients. HOW: Factories must complete self-questionnaires and provide detailed descriptions of their procedures.
THERE ARE THREE STEPS FOR FACTORY QUALIFICATION:
Q A / Q C
1. FACTORY QUALIFICATION
STEP 1: DOCUMENTATION
QUESTIONNAIRE #1: GENERAL BUSINESS QUESTIONNAIRE• Provides basic information about the manufacturer/company as a
whole. • Allows us to get to know the company and gives us basic background
information about the factory.
Q A / Q C
1. FACTORY QUALIFICATION
STEP 1: DOCUMENTATION (continued)
QUESTIONNAIRE #2: GMP QUESTIONNAIRE• Requires the factory to provide a detailed explanation of their
procedures related to cGMP topics. • Questions the factory about procedures related to manufacturing,
packaging, labeling, holding, distribution and quality.• Allows us to get insight on how the factory runs and if they have the
proper procedures in place to maintain the integrity of their products.
Q A / Q C
1. FACTORY QUALIFICATION
STEP 1: DOCUMENTATION (continued)
ADDITIONAL DOCUMENTS• Factory Certifications – as an indicator of standard compliance
• Examples: GMP certification, ISO 9001 (Quality Management Systems), ISO 14001 (Environmental Management), ISO 22000 (Food Safety Management), BRC, FSSC 22000, etc.
• Factory SOPs and related documents – as an indicator of how procedures are implemented & followed through on
• Food Safety Plans – as an indicator of how product safety is taken into account
Q A / Q C
1. FACTORY QUALIFICATION
STEP 2: ON-SITE AUDIT
• Decisions to perform an on-site audit are based on the information gathered during documentation review. On-site audits are performed by either IO’s Quality Control Manager or in-house SGS-trained QA auditor.
• On-site audit includes an intensive 20+ page audit inspection checklist.
• Covers topics ranging from site security to product testing.
Q A / Q C
1. FACTORY QUALIFICATION
STEP 3: FACTORY GRADING
• Factories are initially graded based on how they perform during this qualification process. Factories must exhibit sufficient ability to produce and maintain production in a cGMP compliant manner in order to be qualified.
• Factories are given a score from 0 -100. They must earn at least 70 points to be a qualified factory.
Q A / Q C
1. FACTORY QUALIFICATION
STEP 3: FACTORY GRADING (continued)
As we continue to work with the factory, additional factories are taken into account to determine their grade. This includes:
• Product conformance to specifications• Factory responses to inquiries and complaints• Quantity of quality-related returns• Competitive pricing• On-time shipments and delivery, inventory availability
Q A / Q C
2. INGREDIENT QUALIFICATION
Ingredients are pre-approved before they are added onto the platform.
THERE ARE THREE STEPS FOR INGREDIENT QUALIFICATION:
Q A / Q C
2. INGREDIENT QUALIFICATION
STEP 1: ABILITY
When factories request to introduce a new ingredient onto the platform that isn’t currently existing, we research it first to make sure it’s appropriate for use. This includes searching for:• FDA warnings listed about the product• Known/proven health hazards about the product• Inclusions on the WADA Prohibited List
Q A / Q C
2. INGREDIENT QUALIFICATION
STEP 2: DOCUMENTATION
If there are no issues with the product in general, factories must provide ingredient-specific documentation for review. This includes documents such as:• Specification Sheets• Safety Data Sheets• Sample Certificates of Analyses• Allergen Statements• Composition Statements
Q A / Q C
2. INGREDIENT QUALIFICATION
STEP 3: PACKAGING INFORMATION
• If all supporting documents about the ingredient appear in order, understandable and useful, we will request packaging configuration information. This way, we know what to expect when we receive new products.
• This also allows us to determine if the packaging configuration chosen by the factory is suitable for the product. For example, light sensitive ingredients shouldn’t be packaged in transparent poly bags.
Q A / Q C
3. PRE-SHIPMENT TESTING AND INSPECTION
STEP 1: FIRST DOCUMENTATION REVIEW
• Our China-based QA/QC department reviews and approves product batches before releasing shipments to our U.S. warehouses.
• Certificates of Analyses are reviewed and compared against Specification Sheets.
Q A / Q C
3. PRE-SHIPMENT TESTING AND INSPECTION
STEP 2: MATERIAL REVIEW
• For new products or products that have not been qualified, the QC personnel perform a physical inspection on the material.
• Basic physical tests and microbial contamination tests are performed on the product to ensure compliance to basic specifications.
• The product is physically examined for organoleptics, homogeny and foreign matters.
Q A / Q C
3. PRE-SHIPMENT TESTING AND INSPECTION
STEP 3: SHIPPING CONDITIONS
• Pallet conditions are checked and verified to make sure the product is secured. Pallets must be in good condition and placement of the product onto the pallets must be organized to minimize possible damage during transit.
• Once shipments are received at our U.S. warehouses, our local teams inspect the shipments again to make sure everything is intact and untampered with.
Q A / Q C
4. MATERIAL QUALITY AND CONSISTENCY
RANDOMIZED, PERIODIC TESTING
• We know that adherence to specifications is imperative, so for our own internal peace of mind, we do randomized periodic testing on batches we have in stock to verify manufacturer-provided data.
Q A / Q C
4. MATERIAL QUALITY AND CONSISTENCY
WE TEST THE PRODUCTS AGAINST THE MANUFACTURER’S SPECIFICATIONS FOR:
• IDENTITY• PURITY• STRENGTH• COMPOSITION• LIMITS ON CONTAMINANTS
Q A / Q C
4. MATERIAL QUALITY AND CONSISTENCY
• We only use U.S. laboratories with ISO 17025 accreditation.
• We already have confidence in our factory partners; this just helps strengthen that.
Q A / Q C
5. WAREHOUSING AND CUSTOMIZED SHIPPING
WAREHOUSE SET UP
• Warehousing plans and procedures are established with the goal of efficient order processing and protection against adulteration in mind.
• Products remain properly sealed and stored in good condition to minimize cross-contamination.
Q A / Q C
5. WAREHOUSING AND CUSTOMIZED SHIPPING
ORDER FULFILLMENT
• Any customized shipping requirements you have get recorded into your customer file. This information is reviewed with each one of your orders to ensure that you receive your order the way you want it.
• Before an order is shipped or picked up from our docks, we perform a three-inspection check to make sure the order is fulfilled correctly.