#367 - The Insider's Guide to Supplements: What Every Founder Needs to Know About Compliance, Claims, and Scale

Ramon Berrios: Foreign.

Narrator: This is D2C pod, where the worlds of creators, consumer goods and brands collide. We get behind the wheel to show you how today's biggest products and ideas are made, launched and scaled. If it's shaping the future of commerce and culture, you'll Hear it here first. Catch new episodes weekly on Spotify, Apple Podcasts or D2C pod.com Be sure to check out our newsletter for weekly breakdowns and recaps linked in the show notes. So before we, before we kick off

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Ramon Berrios: Today we are joined by Graham Rigby, who is the president and CEO of the American Herbal Products association, or the ahpa. And he also has a ton of experience working in the space. He's worked as, as the Chief Innovation Officer at Care of and he's worked directly as one of the co founders, um, of Infinite Garden, as well as working on Ingredient AI. So, um, before I get too far into everything, Graham, I'll let you kick us off. Um, you're someone who has a ton of experience in the herbal supplement sort of space. You've been working in this sector for a long time. There's massive changes that have been going on. We've seen some of the biggest brands in wellness and D2C scale in this category. So excited to have you on. So maybe we can just start with a little bit more about your background, how you found yourself into the role and what you spend your time focused on at this intersection between, uh, you know, herbal wellness and direct to consumer.

Graham Rigby: Yeah, thanks for having me. Very excited to be here. Big fan of the pod and obviously

Blaine Bolus: all you do for the, you know,

Graham Rigby: entrepreneurial and just health and wellness community. Um, yeah, as you said, I've been in health products, dietary supplements for the past 20 years, uh, on the industry side and startup side for a lot of it and now leading a trade association sort of tasked with providing education,

Blaine Bolus: guidance and understanding of how best to

Graham Rigby: compete and grow and be compliant in our regulated industry. The industry is thriving. I think herbal products have gone from 2 billion in 2000 to 13.33 billion last year. And that's driven by a number of vectors. One is all these amazing young startups

Blaine Bolus: that, that are happening.

Graham Rigby: Founders are getting companies and they're not

Blaine Bolus: just doing your traditional vitamin mineral preparations,

Graham Rigby: they're focused on herbs. They want stories, they want things that they can kind of tell and their consumers ultimately want feedback and they want

Blaine Bolus: sort of results, uh, from these.

Graham Rigby: And it's not just sort of the age old, how do I age healthily?

Blaine Bolus: You know, I might have some joint concerns. I need things from joint health.

Graham Rigby: People are taking products for beauty, they're

Blaine Bolus: taking it for athletic performance, they're taking it for stress and sleep.

Graham Rigby: And these are benefit areas that are

Blaine Bolus: attracting a whole wider swath of consumers.

Graham Rigby: It's not just sort of, you know, weekend warriors, 45 plus types now that

Blaine Bolus: are looking to supplements.

Graham Rigby: You've got teenagers, you've got college students, you've got people in their 20s looking to look in their field or best and are turning to herbs much sooner

Blaine Bolus: than generations that preceded them.

Ramon Berrios: Um, Graham, that's, that's such a good point in terms of just like how the landscape sort of shift. I think the way you're characterizing it in terms of, uh, you know, there's a lot of marketers who have been able to like, enter the space and tell those compelling stories. Whereas before it was kind of like, you know, you would just go to your local herb shop and get what's on the shelf and it was like, it's a totally different kind of marketing environment. But, um, you know, one thing I want to talk about on this, uh, this episode, well, there's two, two big things that I think we can go into. One is what does this actually mean? Like, how have some of these, the biggest, best in class brands done it? What do they need to know from the regulatory point of view? And um, how have they worked with the AHPA to do it? Um, and the second is, uh, more around like regulation. Obviously we'll get into innovation and stuff, but I want to know, like, what does this space look like? Because I think a lot of times when consumers or brand builders or whatever hear about supplements, like, you know, on the E commerce side, you hear, oh my God, supplements are so hot. Everyone's doing supplements. Every influencer and their, their friend is Launching a supplement. But um, you know, you, and then on the other side you just hear like horror stories of these like supplements that are just sold in gas stations with super sketchy ingredients and all of this. So um, I think there's going to be a lot of us lot for us to unpack. But maybe we start with you know, in the, in the vein of like just DTC and stuff that you've done with leading brands. Like how does the HPA interface and how have you guys like worked with some of um, these bigger brands, uh, that, that are super, you know, household names.

Graham Rigby: Yeah, I mean it's a great question. I think maybe a couple of milestones to put out there for the audience. One is in 1994, uh, there was a landmark legislation passed called the Dietary

Blaine Bolus: Supplement Health and Education act.

Graham Rigby: And that basically created the framework for what we now know as dietary supplements. Over 30 years ago, that sort of

Blaine Bolus: opened the doors to innovation and allowing people to suddenly find herbs, multivitamins, protein powders, a lot of the products that we know as dietary supplements today.

Graham Rigby: But it also created a highly regulated

Blaine Bolus: framework with which FDA would provide oversight. Supplements first and foremost are regulated as

Graham Rigby: food, and they are food supplements.

Blaine Bolus: And so they're obviously food is in the definition, but when you think about

Graham Rigby: capsules and powders and soft gels, they

Blaine Bolus: also look closer to OTC and drugs. And so in addition to that 1994 law, in 2007 Good Manufacturing Practices were mandated by FDA. That came into effect in 2010.

Graham Rigby: And those GMPs, there's a lot of

Blaine Bolus: acronyms in regulated industry.

Graham Rigby: Of course, those good manufacturing practices, they govern how you identify the composition of

Blaine Bolus: your products, how you manufacture them, and how you ensure each specification confirms the identity, potency, composition and purity of each dietary supplement. And so there's a lot of regulation to understand. There's a lot of regulation and guidelines that APPA, you know, the American Herbal

Graham Rigby: Products association, we help companies, especially small

Blaine Bolus: medium sized businesses, understand the regulations, provide templates and ways with which to comply, and then host educational events that provide a way for people to sort of get a, uh, huge download of okay, what are the most important things I need to know? How do I best comply?

Graham Rigby: How do I kind of keep up

Blaine Bolus: with all the regulations and things that aren't just coming from the federal level. Now in 2025, we've seen a lot happen on the state level as well. And APPA and organizations like us, we're there to sort of consume everything that's going on from a regulatory state and federal Government level and provide sort of an extraction of that, that's easy to consume for members so that they can make sure they're compliant and focus on growing their businesses without worrying about any compliance gaps.

Ramon Berrios: So maybe a fun way to kind of like put this would be like, if I'm starting a supplement brand, right, like, what do I need to know about, uh, you know, compliance? Like, how do I do it right, like, uh, you know, do I. You mentioned you need, you might need, um, a GMP facility. You may need certain sort of packaging. There might be certain things that I can and can't say, but let's just use the example of a super traditional, like easy ingredient, nothing super complex. Um, you know, how would a founder go about bringing a supplement brand to market? And what is that minimum value viable sort of thing that they need to do to get an ingredient from some sort of manufacturer, uh, to sell it to a consumer?

Graham Rigby: Yeah, it's a great question. I mean, I think the first is sort of understanding the idea and the consumer framework, right? Which a lot of founders and startups, that's where they start, like, where's the idea? Where can I disrupt this industry? Where's some way to differentiate? The good news is once you have that the dietary supplement industry is a group of, you know, kind of external partners with which you can kind of

Blaine Bolus: build a relationship with to help you

Graham Rigby: with both the sourcing, the manufacture, the

Blaine Bolus: bottling and the labeling of these, uh, products.

Graham Rigby: And so there are many contract manufacturers,

Blaine Bolus: raw material suppliers, you know, sort of

Graham Rigby: label packaging suppliers that are all within both APPA membership and just the industry writ large that are there to sort

Blaine Bolus: of help you understand, uh, all the different things. So it's not like you're going to

Graham Rigby: be flying to India to find ashwagandha

Blaine Bolus: to farm it yourself. You know, you can obviously partner with

Graham Rigby: folks who are expert and have done that, but there are a lot of

Blaine Bolus: responsibilities for the brand itself. Once you've sort of up and running, you do have to create specifications for

Graham Rigby: your products so that your contract manufacturer

Blaine Bolus: knows what they're building, knows what you're looking for. You can work with contract manufacturers, they have R and D teams. You can work with, you know, to sort of understand what are some of the things I want in and out. Do I want a clean label product, Do I want to add any additional ingredients in addition to say, ashwagandha that you might be wanting to formulate with all the way to sort of what is the label going to say and what are the claims? I'm going to be able to make off of those. You need to have kind of those specifications. You need to register with the FDA that now you're sort of a food brand that um, is going forth and you're going to start putting products in.

Graham Rigby: And then one of the things that

Blaine Bolus: is really helpful about that 1994 law

Graham Rigby: we talked about before is it doesn't

Blaine Bolus: require pre market approval. And so you don't have to wait for FDA to go through all your documentation. You have to have all that documentation and compliance ready to go.

Graham Rigby: But you can launch your product and

Blaine Bolus: notify FDA within 30 days of launching it that you've done so, and any claims associated with products you've made.

Graham Rigby: And then the way that the regulations

Blaine Bolus: work is it's a uh, post market surveillance regulatory regime, which means FDA has inspectors that can come to your facility or come to your offices whenever they want in the US unannounced and basically will go through all that documentation. We talked about your specifications, your labeling, your claims, all these things that you have that need to comply with the regulations and they'll do an audit and

Graham Rigby: basically they'll go through all that documentation. They'll, they'll sort of find that you're in full compliance or maybe find a

Blaine Bolus: couple of things that you might need to sort of work on.

Graham Rigby: And then if you get any sort

Blaine Bolus: of observations, you'll have 15 days to

Graham Rigby: kind of submit back to FDA. Here's our corrective action plan.

Blaine Bolus: Here are some things that we can do to, to kind of do this better.

Graham Rigby: And it's a way that FDA can

Blaine Bolus: make industry better while it's out there serving the consumer needs for health and wellness products. And it's pretty unique.

Graham Rigby: Uh, we're very fortunate in the US

Blaine Bolus: to have this innovation friendly environment.

Graham Rigby: But it's not without all of these

Blaine Bolus: compliance requirements that definitely need your attention,

Graham Rigby: which can be overwhelming when you just start out.

Blaine Bolus: It's like, wow, I'm one person or

Graham Rigby: I've got a small founding team. Uh, and so that's where you can kind of rely both on partners, contract

Blaine Bolus: manufacturers, suppliers, as well as trade associations like capa, uh, to kind of help fill in the gaps and have a lot of experienced folks like myself that have done this for a long time

Graham Rigby: to kind of give you some clues

Blaine Bolus: or help, you know, answer some of the questions that might take you a long time to figure out on your own.

Ramon Berrios: And what are the differences? I guess just for, you know, people are listening and I think you kind of alluded to it, but what are the Differences between like a drug, a pharmaceutical drug that's like done and goes through trials and like, has claims versus like a, ah, supplement or a nutraceutical that, you know, you can kind of sell, make sure your, your claims are compliant, you've kind of put it through, um, you've registered with the fda. But I think one thing everyone sees on all these packages is like this statement has not been evaluated by the fda. Right. So like, what's, what's the difference between these two worlds, um, between pharmaceuticals and like these nutraceuticals?

Graham Rigby: Yeah, it's a great question. You know, underpinning all of the Food

Blaine Bolus: and Drug Administration's, you know, efforts is consumer safety. And so like first and foremost, whether

Graham Rigby: it's a drug, whether it's an over the counter drug, or whether it's a food or dietary supplement, safety is obviously the most important thing. And so for a lot of drugs or like new to the world, chemicals that, that are not natural are not found in nature. There's a whole set on series of

Blaine Bolus: safety trials that need to happen from

Graham Rigby: you know, cell culture all the way

Blaine Bolus: through human clinical trials just to prove

Graham Rigby: that it's safe, there's no untoward effects, and then it moves on to sort of efficacy. And that's really in an environment where pharmaceutical uh, company is looking to kind of own that chemical, uh, and then

Blaine Bolus: brand it and obviously have a lot

Graham Rigby: of years of uh, run where they're

Blaine Bolus: the exclusive provider, that is their ip, that's their, their uh, unique uh, way

Graham Rigby: to market, which is obviously lucrative.

Blaine Bolus: And then you go through pharmacists, uh, doctors, prescriptions, everything but that.

Graham Rigby: The way that they get to safety

Blaine Bolus: and efficacy is through multiple clinical trials. Oftentimes because it's completely novel what they're doing, uh, to the world.

Graham Rigby: On the food side, there are several

Blaine Bolus: pathways to prove uh, that something is safe. And once you select an item that has a proven track record for safety, it's in the food supply, it's done

Graham Rigby: sort of significant toxicology work. Then those are things that you build

Blaine Bolus: on within the dietary supplement space.

Graham Rigby: And so something needs to have sort

Blaine Bolus: of an underpinning of safety. It's either been used, uh, you know, as a food stuff or you know, an article of food for a long time predicating, uh, the laws sort of

Graham Rigby: on the books, or it's gone through

Blaine Bolus: this significant rigorous toxicology study and allowed for it to sort of be made a dietary ingredient. And then once you have an ingredient that's sort of past all that, that is an approved dietary ingredient from fda, then it can go into dietary supplements and be sort of manufactured, so long as it's following sort of the, the contours of the approvals that that ingredient has made in terms of its form, its preparation, and in sort of the, the composition that it follows, as well as the dose. You know, there's a pathway for new dietary ingredients that you can petition FDA to say, here's a new, you know,

Graham Rigby: a new botanical that didn't follow some

Blaine Bolus: of those things, you know, an old dietary ingredient or, you know, it's in the food supply and it's generally recognized as safe. Um, so as a new dietary ingredient, you have to sort of prove that that ingredient is safe. FDA review it, and then they'll give you sort of an NDI approval with which you can move forward. So there's lots of gates that you can kind of go through to make sure something is safe. It tends to be faster than pharmaceuticals and tends to require less. Um, but it also offers less in terms of claims, like, if you just have a certain ingredient, there's only so much you can say about it. But many companies like oppa member AG1, they've done several human clinical trials with which now they can make, you know, specific claims on.

Graham Rigby: Hey, AG1 is great for digestive health,

Blaine Bolus: it's great for gut health. We know that is this powerhouse sort of, uh, you know, superfood and super greens beverage.

Graham Rigby: But they've really been able to identify,

Blaine Bolus: through the power of clinical research, more benefit areas that are unique to them.

Graham Rigby: And that's, you know, I think an emerging area, uh, that is now accessible

Blaine Bolus: to founders in a way that it wasn't, you know, I first started and,

Graham Rigby: you know, the mid-2000s, to do a

Blaine Bolus: human clinical trial would cost you $400,000, $500,000.

Graham Rigby: You'd have to have a site, you know, recruited. People would have to drive to the site, they'd get their blood taken, whatever.

Blaine Bolus: Now, in 2025, you know, there are startups like Radical Science, like People Science,

Graham Rigby: you know, again, people that within the app orbit that we could introduce you to if you have questions of talking to these folks. But they're using the power of the smartphone to allow people to sort of

Blaine Bolus: enter in how they're feeling, what's going on, so they can participate in clinical trials at home. And that has brought the cost down significantly. You're talking about 10% or 20% of the cost it would cost 20 years ago. And so that's been a huge boon and allowed, you know, a Lot of these companies to sort of invest in clinical research when they get to a level or when they think they can, you know, use that as a proof point for consumers to get them to say yes.

Graham Rigby: Because there's a lot of options and

Blaine Bolus: there's a lot of ways to a lot of products out there within dietary supplements. So clinical science is one way to differentiate. It's not a requirement for safety per se, but it does help you set yourself apart and differentiate in the ways that we see kind of, you know, ultimately drug companies using clinical research to kind of put forth, uh, benefits that they've proven so slightly different. You know, they're obviously dietary supplements are absolutely not drugs. You know, they don't cure, prevent, treat disease. That's very clear on that little box that you sort of referenced. But the one thing that the Shay box, you know, also says is the FDA doesn't evaluate those statements, which it does you.

Graham Rigby: The that 30 day sort of requirement

Blaine Bolus: that I mentioned before, you send that to FDA and if you make a

Graham Rigby: claim that is, you know, not true

Blaine Bolus: or that it's a drug claim, for example, you say you're curing some disease,

Graham Rigby: the FDA will write you back and say that's not an appropriate dietary supplement claim. Uh, you need to change that.

Blaine Bolus: Otherwise, uh, you know, you'll sort of set off a uh, series of accelerating engagement, um, from the agency that you really don't want. I would not recommend that, uh, you know, you want to sort of comply with appropriate structure function statements that promote the health and wellness of the body versus treating or curing a disease. That's the major distinction in terms of claim structure between food supplements and drugs.

Ramon Berrios: Yeah, And I want to kind of just double click on that because I think that's kind of where rubber meets the road for a lot of marketers. Right. In terms of like, what can you say, versus what can you not say? What is a health claim, what isn't a health claim? I think, you know, right now you're seeing every brand is, you know, backed by science and formulated with so and so, um, and influencers are launching supplements and everything. So, um, you've got a lot of chatter. You've got a lot of, uh, marketers who are, you know, doing their thing, kind of pushing that line, figuring out like, where it is. So what? Just simply put, like, what can you say? What can't you say? Yeah, yeah.

Graham Rigby: And I think, you know, Wayne, this is a really, it's a great question and it's the hardest thing when you

Blaine Bolus: get into health and Wellness startups, because consumers do not think that this way. Right?

Graham Rigby: Consumers aren't like, oh, this is the regulatory framework for dietary supplements. And that does not equal what I see on OTC products. And that does not equal what I see, all the drug advertising that I consume. They just think, oh, I've got something wrong with me, can I take this product for it? But, um, you know, as, as marketers and as you know, startups, we have to sort of evaluate what is appropriate

Blaine Bolus: for a supplement to say, so that we don't delve into or sort of make drug claims which would make the company liable.

Graham Rigby: They're very competitive, but I would say they're not very sustainable over time because if you grow, uh, and you, you

Blaine Bolus: make enough noise, then the regulators will definitely find you and uh, and certainly help you move back to, you know, the dietary supplement sort of contours of claim structure that you should.

Graham Rigby: I think an easy way to think

Blaine Bolus: about it as you're jumping in is

Graham Rigby: additive things that are promoting health and wellness, that are sort of promoting skin hydration and glow and moisturization and not

Blaine Bolus: treating sort of a skin ailment or disease.

Graham Rigby: That's a way, it's sort of like if you think of sort of additive and up to the right versus taking

Blaine Bolus: someone that's sort of in deficit and bringing it back, those are typically good ways to think about it. You're promoting, you're enhancing sort of workout performance, you're doing those things versus kind of treating a negative. Um, oftentimes we think of that way because we're consumers.

Graham Rigby: Um, but we want to promote, you

Blaine Bolus: know, the, the immune system function versus treating anything that our immune system might be fighting, you know, is a good way to kind of divide it up.

Graham Rigby: Clearly the most competitive ways for startups to compete are, you know, right on

Blaine Bolus: the line of those things. And there are many, you know, um, excellent sort of resources to help you. Uh, I would highly recommend as you get going that you identify sort of a capable FDA attorney who can help

Graham Rigby: you understand both, you know, where a

Blaine Bolus: claim can fit and you know, how aggressive or conservative you want to make.

Graham Rigby: And then secondly the substantiation that you

Blaine Bolus: need to have for that claim. Because the more specific or aggressive a claim you have, the more data you need to have to support that as well. Because there's not only sort of FDA regulations to, to worry yourself with, there's also the Federal Trade Commission who, if you're making fraudulent claims, you're making things that aren't substantiated. That's the, the agency that would typically look at that and they have engaged on dietary supplements in the past around immune health and in other areas. And so um, it's something to be mindful of. You both need to sort of meet,

Graham Rigby: you know, what is an appropriate claim

Blaine Bolus: for a dietary supplement that sort of

Graham Rigby: follows promoting the structure and funct the body and health systems and then you

Blaine Bolus: know, on the FTC side making sure you have substantiation to really under, you

Graham Rigby: know, underpin it and then also give your consumers confidence. And the thing I like to say with new members starting up, you know,

Blaine Bolus: and as companies are getting into it, you really want the consumer to have an experience that they can either feel or recognize or trust with the science that you have.

Graham Rigby: Because the worst thing you can do is pay the cost to acquire a consumer and have them churn after one, one bottle or one piece.

Blaine Bolus: Right. Like that's, that is absolutely no way to make on D2C uh, money.

Graham Rigby: And so clearly having things where you've

Blaine Bolus: got a sustainable building approach and something that people can recognize, which often costs a little more than the basic standard, but can pay off in the long run and obviously having higher retention.

Ramon Berrios: Yeah. And I think one other like last question kind of on the the claim side is, is there a distinction? Because I feel like, you know, one of the big things all these brands are doing is they're running all sorts of marketing messaging to like target different indications. Like as you scale, it's just inevitable, right? Like your target for first you just start with one indication and then you're like, wait a minute, this ingredient, you know, does all these different things. So we're going to segment our audience. We're going to target uh, you know, gut health over here, we're going to tug target brain health over here, et cetera, et cetera. So um, how does, is there a difference between what you can say on a label, right, like versus what? Um, you know, you can just convey through, you know, online creative or what other online content creators are sort of saying. Is there any distinction or does it remain the same?

Graham Rigby: Yeah, it's a great question. I mean, I think um, FDA has

Blaine Bolus: said, you know, that it's sort of website or content, uh, that you're creating is sort of de facto labeling, especially if it goes back to the sale of a product, which I'm assuming most content, you know, whether you're on TikTok or Instagram is sort of doing that. Um, there are certainly some rules where you don't have to have all of uh, you know, if you're laddering back to a website having all of the different distinctive, you know, language or the f. The DSHEA box or all the things we've talked about, you know, there's ways to kind of make it, uh,

Graham Rigby: cleaner and more seamless.

Blaine Bolus: So long as that, you know, warning is, is obviously displayed when you get to the product page. And as you're looking to sort of do that, um, you can certainly talk a lot more about your products and sort of bring romance and other angles versus the maybe specific structure, function, claims. And so that's an area you see a lot of people, you know, people are interested, especially younger generations, you know, millennials, Gen Z Alphas. They want to know where their products are coming from. They're very interested in sort of how clean, uh, these ingredients are in the overall format. Are there a lot of preservatives? There are a lot of other things that really aren't health claims at all. They're not, um, given the same regulatory rigor, there's more classic definitions of, uh, is this an artificial preservative or not? Um, and do I have it? Is it something that I can't pronounce, or is it something like rosemary or oregano that's obviously providing, uh, you know, a natural preservative in a fish oil or something like that that you see on the markets.

Graham Rigby: So, um, so I think, you know, there, those guidelines still hold obviously, um,

Blaine Bolus: you know, people take a little bit of latitude. It's easier to sort of take down creative, uh, that pushes the line versus to change your label in some ways. And so you certainly see people doing that. And again, I think, um, these are all calculated choices that being mindful of the regulations and the marketplace, you know, that's, that's kind of the challenge for marketers and founders in this space is finding that niche and sort of that through line of being compliant and competitive, which is a challenge, but it is achievable.

Ramon Berrios: Next thing, I want to switch gears a little bit. I think we've, um, you know, we've covered a fair amount on the, uh, compliance side of things. But I want to talk about like, what are, I want to talk about the industry in of itself, right? Like, I think we see a lot of brands who do really well on the storytelling side, on the ad side, on the ugc, on the creator side that can scale really quickly. But what are some of the channels, uh, in the Nutraceutical, the wellness supplement sort of space that maybe a lot of people don't know about that, um, they can tap into for growth. For example, um, what does the distribution picture look like for retail? How do some of these, uh, brands that are in the supplement space get into retailers? Are there other sort of channels that people may not be thinking about other than their own shop? Obviously driving traffic to your own shop is, you know, one way to do it. You can control the margins, you can control the spend, you can grow up, but at the end of the day you're driving all your own traffic. So, um, I just love to talk about what does this landscape look like? Because a lot of people who are getting into supplements, you know, they're like, oh, like I've got this problem that I want to solve. Oh my God, I can solve it with like this really great ingredient. Okay, I'm going to start driving creative and driving all this stuff to my own site. But they don't come from this industry. They don't know what the picture looks like. So why don't you just characterize, I guess, the broader landscape that isn't D2C, if that makes sense.

Graham Rigby: Yeah, absolutely. I mean, I think, um, you know,

Blaine Bolus: it's funny, like when I first started in dietary supplements, Amazon didn't sell supplements. So this is like 2008, 2009, there were like some people reselling third party on Amazon, but it was, there were many other players, um, like Iherb and Vitacost and others that were the major E comm players at the time. Um, and now obviously Amazon is the biggest supplement store in the world and

Graham Rigby: that's obviously a choice that a lot

Blaine Bolus: of D2C, uh, you know, founders need to make. You know, do I want to go into uh, Amazon in addition to selling direct? A lot of sort of the logistics underpinnings can be shared. A lot of three PLs you might partner with can obviously fulfill Amazon products orders as well as your own D2C.

Graham Rigby: So there is some, um, you know,

Blaine Bolus: sort of overlap there and some synergies in terms of expanding thinking beyond sort of D2C and thinking about, okay, are there other e comm channels that I want to do? Um, you know, TikTok shop is another one that has really sort of come up fast. Uh, a lot of people are selling products if you have like really great, you know, UGC or just sort of content. You know, we've seen brands kind of explode on TikTok shop and then it sort of permeates out from there. There's many other sort of e comm websites that are selling uh, products that once you've stood up a 3 PL that can do E Com, uh, fulfillment, you know, you can easily do that. And then a lot of these retailers, you can also ship them um, product with which they can fulfill through uh, their own orders. So I think that's, that's another possibility.

Graham Rigby: And it's typically the easiest way to

Blaine Bolus: move from D2C to E COM because a lot of the thinking, the spend and sort of the analysis is similar.

Graham Rigby: One of the ways that I learned

Blaine Bolus: though, you know, when I was a care of and uh, within other sort of health and wellness G2C digitally native startups is that you know, channel diversification is the way to kind of um, make sure that you've got, you know, different ways to sort of penetrate the market and there's different risks and certainly costs. Um, you know the reason to go into a brick and mortar retailer like a Target or a Costco or a

Graham Rigby: Whole Foods Market or some of these

Blaine Bolus: is they are acquiring your consumers for you. Right? Like the consumers are walking in the door because they need to get bananas

Graham Rigby: and cereal and protein drinks and whatever

Blaine Bolus: they're there to obviously to kind of get their normal food that, that we're consuming.

Graham Rigby: And so the, the cost to acquire

Blaine Bolus: those consumers is a little bit less. The you give up margin in order to do that. You're not capturing the full consumer margin but you are de risking the idea that our consumer is going to be in that aisle. And you're also adding a different element

Graham Rigby: and that is now I'm sitting next to another brand when I'm communicating with

Blaine Bolus: you directly on Instagram or TikTok or whichever way you're reaching out to your consumers.

Graham Rigby: I have, I'm getting your attention from doom scrolling.

Blaine Bolus: You click on me and I've got you captured, right? And that's the magic of D2C.

Graham Rigby: You need to think harder and longer

Blaine Bolus: about your labeling when you're in aisle at a Target or a Whole Foods because there are a lot of choices

Graham Rigby: and consumers as everyone can represent, we're all consumers. You're not sitting in the aisle for three minutes wondering about this product and thinking of where it was sourced or this brand. You're doing the, you know, 8, 10 second sort of like what's the quick hit? What does this say? Am I interested?

Blaine Bolus: Do I like the branding?

Graham Rigby: Do I like the design?

Blaine Bolus: Does it have the ingredients that I'm looking for? And then it goes in your basket and you're sort of moving. You know, these are.

Graham Rigby: Even though our health is obviously our most important asset, I wouldn't say that

Blaine Bolus: consumers, all of us buying supplements, aren't spending certainly in brick and mortar styles a ton.

Graham Rigby: Oftentimes people will see an ad from

Blaine Bolus: you on D2C and then recognize you in a store. And that's why, you know, many retailers like Target and Costco and others, uh, are actively recruiting D2C brands to come in and giving sort of nice end cap shelf space or promoting these pieces because they want to be seen as sort of the innovative sort of retailer. They want to compete with the E

Graham Rigby: comms of the world and they need

Blaine Bolus: great brands like yours that you're building. And so that often can be sort of uh, a mutually beneficial area of expertise. The cash requirements to get into brick and mortar can be significant. Depending on what retailer. You have to build a lot of inventory and a lot of volume and then sell that in. And so there's different risks. I wouldn't certainly recommend that you do that right out of the gate.

Graham Rigby: But as you're growing, you know, if

Blaine Bolus: you walk through Target right now, you're going to see a lot of brands that, that started as D2C that are now sort of thriving in their like ritual multivitamin or you know, seed, ah, Probiotic or others. You're seeing them sort of come in, you'll see a constant flow of that, um, that I think is important in that diversification. As you look at your Runway and you look at sort of your tam and ways you can access and get

Graham Rigby: to other consumers, there will be more

Blaine Bolus: and more consumers that are in brick and mortar.

Graham Rigby: I think, you know, for E commerce

Blaine Bolus: all in, it's maybe a third of the industry right now in terms of where supplements are sold. Uh, and so there's many more categories, brick and mortar, uh, drug chains like Walgreens or cvs, you know, etc, you know, that's another outlet that obviously sells a lot of supplements. People go in there looking for health products. Um, and uh, and so you know, those, those are others.

Graham Rigby: And then you know, depending on your

Blaine Bolus: product line and where you are, there's also some, some non traditional areas that you could sell in. You know, chiropractor officers, naturopathic officers or sort, uh, of practitioner officers, a practitioner offices, you know, where you're going to see a chiropractor, you're going to see an herbalist or a naturopath. A lot of times those offices in order to make their ends meet because they're not getting insurance money, they're not getting sort of, you know, payment through the classic medical system, they're selling product, and that product is consistent with any advice that they're giving you. Uh, and so that's another potential area where there are some large brands within that space. Because again, if you're going to see a chiropractor, you're going to see a

Graham Rigby: naturopathic physician, more likely or not, you're

Blaine Bolus: going to be invested in sort of purchasing products that they're looking for. And so that can be another one. So, you know, there's quite a few different channels and ways to think about it. That's just sort of, you know, quick, quick overview of some different ways to think about growing beyond D2C alone.

Ramon Berrios: Um, no, that's super helpful. And then, you know, moving forward, I'd love to talk a little bit more about, like, Ingredients, AI and, um, Infinite Garden. And what you guys are starting to see there. I think, like, you know, what we've been talking about is we're kind of at this point where, you know, there's more and more ingredients, there's more and more research, all of it. Uh, you know, there's more ways to drive traffic. Um, so on one hand we've got a market that's more crowded than it's ever been. On the other hand, you've also, like you were saying, the growth just in terms of what people are spending on supplements, like, people are buying into this sort of stuff. And then I think the third tailwind you have is like, just modern lifestyles where, you know, with whether it's the food system or just the ways in which we live, there's more and more appetite for, um, you know, fixing and addressing these sort of problems. So, um, why don't you just take me through, you know, what it is that, you know, you guys are building on those side of things and where you guys see the markets going. Because, like I'm saying, on, on one side of the coin, you could make the argument that, like, okay, this is. This market's, like, way too saturated. Um, you know, AG1's done it, seeds done it, Ritual's done it, and on

Narrator: and on and on.

Ramon Berrios: And on the other hand, you could say, wait a minute, I think there's actually a lot more opportunity here for growth of, like, really great quality brands with the right distribution and the right story and all that good stuff.

Graham Rigby: Yeah, for sure. You know, I think, I think AI

Blaine Bolus: is going to be obviously the disruptive technology, uh, of our time, certainly of the next several years. And I think both of those startups, you know, Ingredient, uh, AI and Infinite

Graham Rigby: Garden, uh, They're both sort of APPA members.

Blaine Bolus: I was on the founding team of both of them and uh, obviously cheer them on.

Graham Rigby: I think the disruption, actually.

Blaine Bolus: Appa, we just launched a technology and AI committee where everyone is interested in how to leverage and deploy AI within, uh, this industry.

Graham Rigby: I kind of bore the audience to death with all these regulations and forms and documents and specifications. But you know what, large language models are really good at creating all of these and filling out all these documents

Blaine Bolus: and sort of creating SOPs and all this language that's structured.

Graham Rigby: And so ingredient AI is really using

Blaine Bolus: large language models to accelerate the way

Graham Rigby: that companies can formulate products, you know,

Blaine Bolus: sort of identify ingredients, identify potential claims from the medical literature that's sort of out there that they've sort of looked at all the way to helping you find contract manufacturers, raw material suppliers, etc. And so they're one of many startups that are sort of in this place,

Graham Rigby: uh, in, in this space, using large

Blaine Bolus: language models with which to connect and summarize the data, but also really identifying some of the pitfalls. And I think one watch out I would have for anyone listening is that

Graham Rigby: you have to be really careful with

Blaine Bolus: a lot of the free large language model interfaces because their data set is the entire Internet.

Graham Rigby: And it might be, you know, Blaine blogging about how much he loves Beats and how it's done this for him, which may or may not be, you know, linked to scientific pedigree or sort

Blaine Bolus: of any, uh, understanding.

Graham Rigby: It may just be, hey, you love Beats and that's great. Um, but you know, ChatGPT or, you know, um, Claude or whatever you might be working with, it's going to evaluate

Blaine Bolus: all of that information and sometimes it can come back. And this happens in all sort of AI prompts, right? You're like, if you have any experts,

Graham Rigby: expertise and, and you get something that's

Blaine Bolus: not quite right, you're like, are you sure about that?

Graham Rigby: And then you get the prompt. It's like, oh, no, sorry, that's wrong.

Blaine Bolus: It's actually this thing that's totally different.

Graham Rigby: When you're doing health and wellness products,

Blaine Bolus: it literally can be life and death, right? Like it, it can be. And the reason all these regulations exist

Graham Rigby: is because people are literally putting what

Blaine Bolus: you're making in their bodies. And so that is a huge responsibility for us, you know, as, as sort of founders, as entrepreneurs, and certainly as, you know, folks who are trying to promote responsible commerce, which is what we do at appa.

Graham Rigby: And so, you know, Ingredient AI, um,

Blaine Bolus: Apex Compliance, there's a bunch of, you know, AI startups within the space that are limiting the data set so that the output from the large language model can be more controlled, reduce hallucinations, and much higher degree of confidence. And that's a really good thing because a lot of the doctors, practitioners that are formulating products, they've been scared away from AI in a lot of ways

Graham Rigby: because, you know, it's sort of created

Blaine Bolus: this false sense or given you the wrong answer. And then all of a sudden they're like, I can't trust it. AI is only getting better and better, though. And so the, the beauty of a lot of these innovators and pioneers is that they can help sort of work out some of those kinks, ensure trust, and then also really control that data set to make sure the output is 100%. So they're definitely worth checking out. And I think they're only getting better as the technology gets better. And I think those who kind of evaluate the way to incorporate AI will, you know, be much further ahead than those that don't, for sure.

Ramon Berrios: Talk to me. This one's going to be a fun one. Talk to me about the sort of, like, intersection that we're starting to see between traditional medical doctors and the supplements industry. I think one thing that's been so fascinating for me to see just because, like, I have a lot of friends who, you know, my dad was a doctor, a lot of my friends have, like, gone through it. And you've got, you know, some of the smartest, like, people in the world who, like, you know, on one side they'll be like, oh, my God, like, they'll just kind of look at these, like, Dr. Content creators and be like, oh, my God, this guy doesn't have a degree, doesn't know what the hell he's talking about, but he has a million followers. But then you also have really successful, really credentialed doctors who are also great at content. And I'm, um, we're just starting to see kind of like this shift happen where you've got doctors who are also creating content and then doctors who are also recommending supplements. You know, they, they know all the information now. They're starting to see the benefits of a lot of these Nutraceuticals where they're actually recommending, um, products that are in the health and wellness space that maybe aren't necessarily a pharmaceutical. So you're kind of getting this crossover. So how do you see this landscape sort of evolving and crossing between, like, the modern doctor and like, the online content creator and the supplements industry?

Graham Rigby: Yeah, it's a great question. Um, you know, I think historically, um, the amount of sort of health and

Blaine Bolus: wellness nutritional information that classic medical schools have taught, you know, burgeoning doctors has

Graham Rigby: been limited to 90 minute seminar or something. You know, this is not an area

Blaine Bolus: that they go deep.

Graham Rigby: You think about a three year program plus your residency, plus all of this. And so what we found is a

Blaine Bolus: lot of times, you know, doctors are learning about products from their patients, you know, and they're saying, hey, you know, I'm taking this, what do you think? And just in terms of like patient service, I think some doctors have, have wanted to get educated and sort of understand what's happening out there. The other huge underpinning is that the cost of healthcare is kind of out of control. That's obviously why the government's been shut down right now. There's some signs that it might reopen,

Graham Rigby: but at least there's been huge, you

Blaine Bolus: know, sort of focus on as everyone's sort of getting their insurance, uh, premiums this month.

Graham Rigby: It's, everything's going up.

Blaine Bolus: And um, the reason that there's so much interest in self care and that is health and wellness products that you would buy yourself to promote your own health and wellness is one avoiding huge medical bills that they can have there. And when you go to, you know, your traditional sort of general, uh, practitioner, you go for your medical health cup, there's not a lot of things that

Graham Rigby: are prescribed to you to promote health and wellness.

Blaine Bolus: When you think about it, right? If you have a problem, you're having

Graham Rigby: an issue, if you're dealing with some

Blaine Bolus: disease, there's a lot of recommendations and prescriptions. If you're just like, hey, you know,

Graham Rigby: I want to get leaner and I'm

Blaine Bolus: worried about, you know, sort of, um, uh, my skin and some things you're

Graham Rigby: trying to promote, that's not where your

Blaine Bolus: traditional doctor's office visit is sort of going to help you. And so people do want those things and so they go looking for credentialed people online. And as you're saying, there are some people that are incredibly well educated, um, promoting things that make sense. And even for consumers, it's like we're relying on our 8th grade health class in a lot of ways.

Graham Rigby: We weren't taught how to take care of ourselves. Right. Like this was not something that was

Blaine Bolus: programmed into our education.

Graham Rigby: I, you know, I made the comment about medical schools. I would say education in general, there's

Blaine Bolus: not a lot about.

Graham Rigby: Unless you study exercise physiology or you

Blaine Bolus: understand Nutrition, you sort of choose to do those things.

Graham Rigby: You know, basic education doesn't do that. And so we as adults, you know, we. We turn 18 and we're like, now we got to figure it out ourselves, right? It's like, okay, uh, I gotta work now, and I've gotta. Got all these things.

Blaine Bolus: I'm stressed out, I'm trying to work out, I'm trying to make it all work.

Graham Rigby: But so people that are compelling content, that are giving sort of, hey, here's

Blaine Bolus: a way to address the thing that's going on with you. That's why it's so appealing to us,

Graham Rigby: is there's an information gap we're trying to solve.

Blaine Bolus: These are not things that our traditional

Graham Rigby: medical system is giving us because they

Blaine Bolus: don't have the training or really the time. You think about the average hospital, you

Graham Rigby: know, annual, uh, physical Visit is like eight to 10 minutes. You know, is there not. There's not a lot of time to converse or sort of go through what

Blaine Bolus: it is you're dealing with?

Graham Rigby: And so we spend a lot more time on our phones.

Blaine Bolus: We spend a lot more time getting information.

Graham Rigby: And so that's where, if you're a compelling physician or credentialed person who has

Blaine Bolus: a story to tell and is meeting an information or filling an information gap, you have.

Graham Rigby: That's why I think you've seen this

Blaine Bolus: explosion in, um, online influencers that have pedigree, and some are great and some are not, you know, to your point.

Graham Rigby: And so it's up to us to have that buyer beware.

Blaine Bolus: But that's why you see such a, you know, huge explosion of these influencers and people that we're looking to for health and wellness advice.

Ramon Berrios: And where do you think, uh, we go? Like, how would you characterize just the, um, you know, this natural supplement sort of space? Do you see it continuing to grow at the same trajectory that, um, we've seen over the last couple years? At what point is there market fatigue? I know a lot of people are like, oh, my God, I'm taking so many supplements. Like, how many do I actually need? Um, do. How do you see some of these trends that we're seeing where, um, people are turning to, like, more things like blood tests and regular tracking, maybe even outside of, like, the doctor's practices. Like, how do you see that, um, you know, driving the, the supplements and wellness space forward?

Graham Rigby: Yeah, I mean, I think. I think diagnostics, um, and, you know, wearable devices, uh, you know, these are

Blaine Bolus: all driving a conversation about thinking about your health status on a Daily basis,

Graham Rigby: which is not a new concept, by the way. A lot of, you know, botanical products

Blaine Bolus: now are inspired by Ayurveda, sort of the ancient heal system of India.

Graham Rigby: And in that healing system there is

Blaine Bolus: both sort of your constitution that, that you sort of are born with. And you know, there's sort of nine different types, there's three major types and sort of nine total types that you can be. But there's also an understanding of sort of your Prakrithi, sort of your, your daily. Where are you compared to your balance point?

Graham Rigby: And I think in some ways these

Blaine Bolus: devices and blood tests are allowing us to sort of understand what is sort

Graham Rigby: of normal and healthy for me.

Blaine Bolus: And then when things get awry and

Graham Rigby: you know, one of the things that's

Blaine Bolus: happening from a societal standpoint that's fascinating is, you know, it was a Gallup poll recently that showed that Americans are consuming less alcohol, the least amount of alcohol than they have in 90 years.

Graham Rigby: And you know, I think one of the reasons is if any of you

Blaine Bolus: have a wearable and you've ever had a night of libations, your wearable has

Graham Rigby: told you that you did not get good rest and your sleep was not good. And whether you felt woke up and it was okay, uh, or not because

Blaine Bolus: it was an awesome night, there's a

Graham Rigby: reminder that there's sort of this unintended

Blaine Bolus: cost of, you know, having a good time.

Graham Rigby: And so the proliferation of people looking

Blaine Bolus: to kava and other botanicals, you know,

Graham Rigby: for sort of a fun, you know,

Blaine Bolus: sort of stress relieving experience and one that doesn't involve alcohol. I think that's something that's sort of out there and going to continue and

Graham Rigby: will drive behavior towards botanicals both on the promoting health and wellness. But you also can see, you know,

Blaine Bolus: and kava is sort of a good

Graham Rigby: example where people like, they're just looking to relax.

Blaine Bolus: They're looking for something that has been known and people have been taking for centuries to kind of, um, you know,

Graham Rigby: relax and chill out and just sort

Blaine Bolus: of take, take a beat on a Friday night or whatever. And so you've seen this proliferation of

Graham Rigby: kava bars, not only in places like

Blaine Bolus: New York City, where you might, but there's hundreds in Florida. You know, there's, there's sort of this proliferation as people are looking to drink less but still socialize and sort of be there.

Graham Rigby: Um, I think that the idea that

Blaine Bolus: companies are investing in science is also engendering trust.

Graham Rigby: And the more you get results, health and wellness can be, um, there's A

Blaine Bolus: momentum factor involved, right?

Graham Rigby: It's like once you start to see

Blaine Bolus: some results, you get hungry for more. You're like, ooh, you know, I suddenly

Graham Rigby: am seeing a muscle that I didn't know I had. And, like, I want to keep working. This is working.

Blaine Bolus: And so I'm going to keep taking my creatine or I'm going to, you know, I've seen sort of something happen with my skin, complexion, or I've seen my hair, you know, sort of improve in a way that I was hoping it would.

Graham Rigby: And so those things, once you sort of have that formative experience, you start

Blaine Bolus: to trust and add more products to the mix. As you're looking to solve some things.

Graham Rigby: You might also say, hey, I'm going

Blaine Bolus: to run the Miami Marathon next year.

Graham Rigby: And all of a sudden, I care

Blaine Bolus: a lot more about exercise recovery and joint health than I did when I was, you know, uh, doing whatever it was I was doing before I decided to run a marathon.

Graham Rigby: And so people come in and out.

Blaine Bolus: You have a pregnancy, all of a

Graham Rigby: sudden, you know, the, the nutrients you're

Blaine Bolus: eating for two, your blood supply goes up 30%, you need more iron, you need more nutrients. And so I think that's always going to happen. And I think the idea that we can be more personalized in our nutrition programs, whether it's through technology, blood testing, like you said, there will always be the need to help fill in some of the gaps or promote things that those diagnostics are telling us. And I think herbal products and natural products will always have a role to play, if not a bigger role, as people get more in tune with their health and want to live longer. I don't think longevity, which is what a lot of people are searching for, is a trend. I think clearly, you know, people have been looking for these, uh, to, you

Graham Rigby: know, looking for ways to kind of live longer and not only live longer. I think, you know, getting to a

Blaine Bolus: certain age is one thing. Healthy life expectancy is sort of what people are really chasing, right? Like, no one wants to be confined or restricted from doing the things they love or just sort of surviving. People want to be active and sort of have this healthy lifestyle long into their later years. And so the more you can sort of get in tune with your body and invest in your health and wellness when you're younger, the more that pays dividends, obviously longer. And I think all these things are sort of converging in a way that's bringing up great interest within health and wellness.

Graham Rigby: So the trends are very strong.

Blaine Bolus: The cagr is super strong on dietary supplements and health and products. It's like six and a half percent on a 70 billion categories are big numbers. And so I think the only other advice I would have to founders is like, don't get intimidated because one person did it.

Graham Rigby: It's a $70 billion industry with a

Blaine Bolus: six and a half percent CAGR. If you do it right and find your sort of niche to consumers, you can kind of break through. And there are many, many companies, uh, that are doing that now. And it's a growing category where, again, all these other socioeconomic factors, our healthcare system are driving people to take care of themselves in a way that historically they haven't.

Ramon Berrios: Graham, I want to thank you for coming on the pod. Um, we covered everything, went super in depth. This was a super fun conversation for anyone who's like, tuning in, um, wants to get in touch. Where can they learn more about you? Appa, uh, where do we connect? Are you guys on socials? Why don't you shout out, um, best places to get in touch?

Graham Rigby: Yeah, that'd be great. I mean, anyone we can follow us on, uh, all the socials, LinkedIn, Instagram, Facebook, you can reach out to me, DM me on LinkedIn, uh, would happy to sort of provide more information about Appa, share some of my experiences, and then we can kind of welcome in, give a sense of how we support founders. And one of the other things we're looking to do next year is to actually do a small business bootcamp focused on health and wellness. D2C, uh, founders and sort of new companies that are looking to learn the regulations and get, you know, some of

Blaine Bolus: the education that we touched on a little bit.

Graham Rigby: So stay tuned for that. We're going to be working, see if we can't get something with the DSC pod guys and Appa as a collab, um, in 2026. So more on that and check our socials for that.

Blaine Bolus: We'll certainly be promoting it.

Ramon Berrios: Awesome. Um, thanks so much, Graham.

Graham Rigby: Thanks, Blaine.

Blaine Bolus: Appreciate it.

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Ramon Berrios: A rating and review would go a

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