CRN Task Force Proposition to CSS

Fellow CSS Members, 

Please review the attached letter from CRN President, Steve Mister. 


September 22, 2015

Dear Robert, Jeffrey and Sara,

I read with interest recently the press release announcing the creation of a new trade association, the Coalition for Supplement Sustainability (CSS), which lists your company as one of its founding members. As I understand the announcement, the primary mission of the group is to develop widely-accepted standards for the certification of dietary supplements as being "GMO-free." In particular, I realize that the companies involved have a pressing need to develop a standard that might allow supplement manufacturers and marketers to certify their products as being "GMO-free" in advance of the deadline Whole Foods has imposed for products in its stores.

After discussing this matter with CRN's Executive Committee, I am writing to you, at its direction, to invite you and other members of the Coalition to consider bringing your work under the auspices of CRN. CRN has a history of establishing various working groups of interested companies to tackle particular challenges that face a segment of the industry. CRN's commitment to science-based solutions, its credibility as a voice of responsibility for the supplement industry, and our staff expertise at managing projects through to consensus and completion would all benefit your objectives.  We see the creation of verifiable and widely-accepted criteria for establishing if a product is free of genetically engineered ingredients as an important and pressing challenge. Thus, CRN would be pleased to add our voice and expertise to this project in the service of the industry and our members who are involved with this effort.

We are open to conversation about the model of governance for your group within the CRN umbrella, but would suggest, as a starting point, that the group could become a Task Force of CRN. Under that model, the group would have access to CRN's staff for both administrative and logistical support, along with our scientists and legal counsel. The Task Force would have freedom to continue its work to develop non-GMO standards for dietary supplements, subject to periodic updates to CRN's Board of Directors.

I understand that about half of the CSS members are already members of CRN and there was concern among the others that alignment with CRN might require them to join CRN. Let me assure you that, while we would enjoy the opportunity to promote the benefits of CRN membership among the CSS members, under the model we envision, CRN membership would not be required for participation in the Task Force, nor would there be any disadvantage to those companies continuing with the CSS but choosing not to join CRN. There is precedent for such a model with our former CRN Omega-3 Working Group (which eventually spun off to become GOED). In fact, in that case, over half the members of the group were not CRN members. It was only when the mission of that group evolved from developing quality standards and scientific evaluations of omega-3s to marketing and promotion of these products beyond what CRN could provide that the group separated from CRN with our well wishes.

With regard to financing your activities, CRN would be happy to handle the accounting issues and bill the Task Force members on a pro-rata basis for out-of-pocket expenses of the group (such as outside consultants or advisors) as the group determines. CRN would not require separate payment for CRN staff resources unless the Task Force's work began to consume considerable staff time, and even in that case, we would work to find a cost-efficient manner to cover CRN's overhead expenses-likely much more cost-effectively than having a separate management consultant.

I would ask that you share this proposal with your members and consider this invitation to explore a collaboration between CSS and CRN. I look forward to your reply and would hope that we could proceed with further conversations in advance of CRN's December Board of Directors meeting so that if any official actions from the Board are required, we could accomplish it at that time. I will look forward to learning of your members' interest.

With warm regards,
Steve Mister
President & CEO
Council for Responsible Nutrition

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