New Vendor Launch! Thrivous.com

Thanks for getting back to me so quickly. I am going to address each point one by one. Again, I apologize if I come off a bit harsh.

In fact, the amount of information we're willing to share publicly has shocked some veterans of the dietary supplement industry. One commented to me that "very unusual" would be under-stating just how unusual Thrivous actually is.

It's good you are being open. I have no doubt that you want to build trust. I do have some doubt in the competency of your lab and production company, though. I will explain why in a minute.

In that, I'll appeal to your sense of normalcy for the dietary supplement industry in contrast to my behavior here. Surely, if Thrivous were more concerned about hiding than sharing, we would not have introduced ourselves as we have. We would have withheld our formula behind a proprietary blend. We would have withheld our CoAs. And in such withholdings, we would still have solid legality and broad precedent on our side. But we've chosen to share as much as we can, in part because we think the precedent should change.

Again, I am very happy that you released the amounts of each ingredient. While this is not the industry standard yet, it will be if I have anything to do with it. Things are changing, and customers not only realize they want to know exactly what they are ingesting, but they deserve to. Vendors that obfuscate, and hide behind the status quo, are going to be dropping left and right in the coming years. Open and honest disclosures are the only way a company can survive in a world where people have almost the entirety of human knowledge and information at their fingertips. The internet has changed the world, and those hanging on to the status quo will go down with that sinking ship.

You asked about Contract Testing Laboratories of America (CTLA). CTLA is a new company, and the secondary test lab for most of the ingredients in Clarity.

The whole CTLA thing still has me a bit concerned. It's billing itself as a 3rd party lab, but is owned by the guy producing your product. There is no history of business there, and no trust in the analytical world. It could just be a shell company for all anyone knows. If I were to create a company producing products for people, and I wanted it to look like a 3rd party lab was testing everything, creating a new LLC like that would be the way to go. I am sure you can understand how it looks.

CTLA tells me that "5413 - Architectural, Engineering, and Related" was the closest to describing its activities among available options in the checklist at the time of incorporation.

That seems odd to me, since his other companies (IDH and CRL) are classified as (3119-Other Food Manufacturing) and (5419-Other Professional, Scientific, and Technical Services), respectively. CTLA should be classified as (541380 - Testing Laboratories), or at the very least (5419-Other Professional, Scientific, and Technical Services), like his other analytical testing LLC. Doesn't it seem strange that the guy that owns multiple LLCs related to analytical testing claims to not know the proper NAICS code to use? Here is how I interpret an unbiased 3rd party looking into this would see it. A shell LLC was created to act as a testing lab for his manufacturing company, and to shield his other LLC, which most likely owns the equipment. So if something turns out to be impure later on, that they certified as pure, they can shut down that LLC, and it would not affect the others. It's a legal insulator, if you will. The issue with that is the CTLA entity has no trust or weight to their word in that scenario. It's simply a shell company. Now I am not saying that is what he meant to do. However, that is what it looks like to an outside observer.

My understanding is that FTIR can distinguish species of plants. So if the composition of an ingredient changes from one species to another, FTIR should catch that. However, if a plant species is misidentified from the beginning and its composition remains consistent, FTIR may not catch that. It seems that the same would be true for HP-TLC and HPLC, although I'm not an expert in these test methods. In any case, the main point is that I think FTIR should be sufficient for Thrivous' secondary test needs at present as long as the plant species are correctly identified from the beginning (in some cases via HP-TLC or HPLC as indicated on primary CoAs).

This is not correct. FTIR is a fantastic device for identification of pure compounds. So your zinc or L-Theanine would be a very good candidate to use FTIR on for identity. It can also be used to assess purity, if you have an accurate enough FTIR (Like our Thermo Scientific IS50), and a valid reference sample (Like from Sigma Aldrich or USP). You can also create your own reference standard, if you have an HPLC and valid methods. It's an amazing tool, and we use it all the time. It can see minute difference in the chemical makeup of a pure compound, due to the way IR light interacts with functional groups in a molecule. What it is not an amazing tool for is natural extracts. That's because most of a natural extract is actually cellulose, since it is coming from a plant. So most natural extracts are going to look very very similar on an FTIR.

Here is an FTIR spectrum of a sample of Rhodiola Rosea 3% salidrosides overlayed on Rhodeola Rosea 3% rosavins.

See how similar they are? You cannot reliably tell the difference.

Now take a look at an overlay of two difference batches of Rhodiola Rosea 3% rosavins.

See how the two batches of the exact same compound are more different than a rosavin and salidroside batch to each other? FTIR cannot tell the difference, because the is too much cellulose in the sample.

Now look at a spectrum of Rhodiola Rosea 3% rosavins from Solaray compared to Ashwagandha!

They are almost exactly the same as the other rhodiola samples, and it is not only a totally different species, but a totally different family of plant altogether. Cellulose is cellulose, no matter what plant it comes from. The infrared light is going to absorb into the cellulose the same. So FTIR is not the appropriate tool to determine species, or minor active ingredients in a plant extract.

Now let's analyze them with HP-TLC and HPLC.

Here is the HP-TLC from a Rhodiola Rosea 3% rosavin sample. It's on lane 5 of the chromatograph.

Here is the HP-TLC from a Rhodiola Rosea 3% salidroside. It's on lane 4 of the chromatograph.

See how the chromatograph can tell the difference in the species, compared to the reference standards on lane 7 and 8, which are Rhodiola Crenulata? The two species give off very different signatures in the chromatograph. If we were using a 3% Salidroside extract from Rhodiola Crenulata, then we would have a signature more like lane 7 and 8. Now let's look at the HPLC reports.

Here is the HPLC from a Rhodiola Rosea 3% rosavin sample. You can see the retention times and percentages for the individual rosavins add up to about 3.4%. That's in spec.

Here is the HPLC from a Rhodiola Rosea 3% salidroside sample. You can see the retention time and percentage for salidroside adds up to about 4.2%. That's also in spec.

So you can see how HP-TLC and HPLC are the only reliable ways to determine whether or not you have an extract from the appropriate species, and whether or not you have the stated rosavin/salidroside content. Yes it costs more. However, you cannot trust Chinese suppliers at their word. We catch so many mislabeled or impure things, you would be very surprised. They LOVE to send you Rhodiola Crenulata instead of Rhodiola Rosea, because it costs them less. That is why it is one of the most mislabeled natural extracts at the moment. Reliable testing is key to building trust with your customers. Panax Ginseng is another that is very commonly mislabeled. So HP-TLC and HPLC are a must there too.

Regarding the other issues with the entities involved, it raises a lot of red flags that everyone involved in this whole endeavor was incorporated last year. Origin is a brand new manufacturer created last year, who has an owner that is also the one who formed the testing lab CTLA last year. Your company was just recently formed as well. So not one company involved in the production and testing of the ingredients or products has been around long enough to be considered a trusted source. The suppliers are Chinese, and their COAs should be taken with a grain of salt. There is virtually no recourse against a Chinese supplier that either knowingly, or unknowingly, sells mislabeled or impure products. This is why testing from a trusted lab stateside is a must for any supplement company. We've literally been sent DXM (Dextromethorphan) before labeled as a nootropic. If that was sent out to customers, it would be very very bad. I would love to see the FTIR spectra from CTLA, though. That would get rid of a little doubt about whether testing was taking place or not, even though the methods are not appropriate for the natural extracts.