In Michael’s wake, I have often described his enduring legacy as a garden—reminiscent of the flourishing urban garden he cultivated from the ground up on an unassuming plot across the street from his home in Venice, California. His tireless commitment—shared by the AHPA staff and his many friends and colleagues in the industry—was to nurture this metaphorical herbal industry garden, ensuring that responsible commerce and consumer access to safe, high-quality herbal products and dietary supplements could flourish within its borders. As we look ahead, we honor his work by dedicating ourselves to continuing to tend to the needs of the industry he helped shape.
Market momentum and evolving consumer demand
Recent trends have cemented the dietary supplement industry’s trajectory of significant sustained growth, with the herbals category leading the charge. Herbal products achieved the highest percentage growth of any category in e-commerce sales in 2024. This market surge appears driven by shifting consumer priorities, notably the demand for holistic wellness solutions and the popularity of adaptogens for stress, immune and mood support. The market has also benefited from the early adoption of dietary supplements by Millennial and Gen Z consumers, who are integrating products into areas like sports nutrition, sleep, biohacking and “beauty from within.”
Beyond product selection, ethical considerations are now key business differentiators, making sustainability, traceability and clean-label transparency crucial to consumer choice. This heightened emphasis on ethical sourcing and quality can be seen in expanded industry efforts in organic and regenerative agriculture for both cultivated and wildcrafted botanical materials. Consumers, especially from younger generations, are inspired by the origin stories and care taken in sourcing their dietary supplements, particularly herbal products.
Trade policy and legislative advocacy
While industry growth is strong, tariffs continue to pose a significant sourcing challenge, especially for essential botanicals that cannot be produced domestically to meet market demand—officially referred to as “unavailable natural resources.” Our initial advocacy efforts have yielded tangible, sequenced results, fundamentally changing the policy discussion from “if” to “how” we achieve relief.
In September 2025, the White House issued an Executive Order creating Annex III, which explicitly acknowledged the concept of “unavailable natural resources” as a basis for tariff relief for the first time. This was a crucial first step, although Annex III commodities are only candidates for a zero percent reciprocal tariff rate contingent upon a final bilateral trade agreement. Following this, a subsequent Executive Order in November 2025 revised and expanded Annex II, creating a more definitive form of relief. This resulted in the full exemption from reciprocal tariffs for major, naturally unavailable commodities critical to AHPA members, including green and black tea (Camellia sinensis), cinnamon, ginger, fenugreek and turmeric (powdered botanical forms).
In total, 57 distinct tariff codes that AHPA members import against are now fully exempt from the significant impact of tariffs. This represents major progress, given that zero botanical tariff codes were granted relief as of April. While this progress is significant, it is not complete. AHPA continues to advocate for additional items that need tariff relief due to their lack of sourcing options in the U.S., including many herbal extracts and several other herbs not yet included in exemptions such as psyllium, ashwagandha, Bacopa and Boswellia.
On the domestic policy front, the U.S. Department of Health and Human Services (HHS) is driving a “Make America Healthy Again” (MAHA) focus, which presents a potential opportunity to increase consumer access to natural products. AHPA is engaged in ongoing talks proposing sensible regulatory reforms to the U.S. Food and Drug Administration (FDA) to help ensure responsible commerce and promote innovation for an industry crucial to addressing the ongoing health care affordability crisis. MAHA’s focus on regenerative and organic agriculture also presents an opportunity for many AHPA members who are farming in this progressive way.
Regulatory clarity and ambiguity
Also in September of this year, a critical legal development unfolded with FDA’s reversal on the status of nicotinamide mononucleotide (NMN). FDA now asserts that NMN is not excluded from the legal definition of a dietary supplement under the drug preclusion clause. This decision acknowledged evidence that NMN was marketed as a dietary supplement before its formal authorization for investigation as a new drug. While the immediate outcome is favorable to the industry, it introduces regulatory ambiguity regarding how the agency will evaluate “prior marketing” in future cases.
As the year comes to a close, the industry is closely monitoring potential changes to the Generally Recognized as Safe (GRAS) pathway. AHPA has long recognized the self-affirmed GRAS process as an important, legal and rigorous pathway. However, FDA’s announcement of its intention to issue a proposed rule that would require mandatory GRAS notifications marks a fundamental shift in how this pathway has traditionally been utilized. While AHPA supports transparency, we are committed to engaging with FDA and HHS throughout this rulemaking to avoid unintended market disruption and ensure continued access to safe, health-promoting dietary supplements and a clear path to ingredient innovation.
Looking forward
The coming year is expected to feature continued, robust growth of herbal products and dietary supplements in an environment that will likely include continued changes to trade policy and both ongoing regulatory reform and legislative activity at the state and federal levels.
As part of this outlook, anticipation remains high for forthcoming guidance documents on the New Dietary Ingredient Notification (NDIN) process. Furthermore, the industry will be closely watching for the release of new dietary guidelines for Americans, which will set the official nutrition policy for the nation guided by the MAHA agenda at HHS.
AHPA in turn will focus on the creation and revision of critical guidance documents to best help industry responsibly comply with regulations, including those for cGMPs (current Good Manufacturing Practices). AHPA worked closely with FDA on industry concerns surrounding use of process controls to ensure conformance with specifications and looks forward to continued collaboration on this critical topic.
AHPA will also continue to focus on responsible use of AI for its members and the broader industry. There is much work to be done on this critical topic, and the interest and engagement among members of our new Technology & AI Committee has been significant.
Following the November enactment of H.R. 5371, which will revise the definition of “hemp” in a year’s time, 2026 will prove to be a pivotal year for the hemp industry. AHPA will continue its longstanding engagement and support for hemp through advocacy for new regulatory frameworks necessary to address these impending legislative changes, which would significantly impact the industry. AHPA views this as a major opportunity for new legislation that provides responsible regulatory frameworks that foster consumer safety, access to hemp products and overall responsible hemp industry growth.
As AHPA moves forward, our focus remains on ensuring the conditions are right for Michael’s “garden” to thrive. Through continued collaboration, robust advocacy and a deep commitment to quality, we will meet the challenges ahead and secure the future for our natural products community.
