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A few months ago, a close friend from Europe -- also a long-time colleague in biopharma -- was visiting us here in Philadelphia. After coming home from a scrumptous dinner, she casually recommended that I try a supplement called Dose. Her pitch was simple: it was a daily “shot” (i.e., a drink in a single gulp) designed to support liver health, and she had made it part of her routine.
I tried it. It tasted good. So I ordered it on Amazon, along with Dose’s cholesterol-support product, largely out of curiosity.
What arrived was not surprising in format: 3 small bottles that fit nicely in the fridge, vaguely citrusy in taste, easy to consume with their little elegant shot glass. What was surprising was what came next: a steady cadence of highly professional, well-written emails containing educational content, and references to clinical studies. As someone who has tested A LOT of pharma messaging over the years, the language felt exceedingly familiar. Familiar in the way good brand teams talk about clinical studies, evidence, and favorable feedback but...sans all of the prominent safety language.
The whole experience crystallized something that many in our industry have been sensing for years: the supplement industry is no longer operating like the Wild West. It is maturing -- commercially, narratively, and strategically. And that evolution has real implications for those of us who market prescription medications.
Historically, supplements occupied a very different mental territory amongst consumers. They were adjacent to wellness, often vague in benefit, and marketed with a blend of aspiration and ambiguity. We've all heard these claims: “Supports immune health.” “Promotes vitality.” The bar for credibility was low, and expectations were lower.
However, that bar has moved.
Brands like Dose and Thorne now package and present themselves less as supplement companies and more as consumer health companies. Their websites prominently feature clinical study summaries, ingredient rationales, and customer testimonials that read almost like patient-reported outcomes. The visual language borrows from biotech and DTC pharma alike: clean design, scientific typography, and restrained claims that feel evidence-based, even when they stop short of approved prescription disease treatment.
For the consumer, this creates a powerful impression: the product feels studied, intentional, and serious. More importantly, it sits comfortably alongside prescription therapies in the same therapeutic conversations -- liver health, cholesterol, metabolic wellness -- without the friction of a physician visit or prior authorization. For someone actively working on treatments for hyperlipidemia and MASH, this was a quiet but unmistakable wake-up call, and one worth sharing with industry peers.
To understand why this matters, it’s worth revisiting how differently supplements and prescription drugs are regulated in the United States.
Under the Dietary Supplement Health and Education Act (DSHEA) of 1994, supplements are regulated as a category of food, not drugs. Manufacturers do not require FDA approval before marketing a supplement. They are responsible for ensuring safety and truthful labeling, but they are not required to demonstrate efficacy through randomized controlled trials prior to launch.
By contrast, as all of us painfully know, prescription drugs undergo years of preclinical testing, phased clinical trials, FDA review, and post-marketing surveillance. Claims are heavily scrutinized. Language is negotiated. Promotion is tightly controlled, both in content and in audience.
The key distinction lies in claims. Supplements may not claim to diagnose, treat, cure, or prevent a disease. Instead, they rely on “structure/function” claims: statements about supporting normal bodily functions. These claims must be accompanied by a disclaimer noting that the FDA has not evaluated the statement.
From a regulatory standpoint, the line is clear.
However, from a consumer standpoint, it is anything but.
Most consumers do not understand regulatory frameworks -- and that is not a criticism. I know this from years of conversations about questions as basic as, “What does FDA approval actually mean?” Consumers do not parse statutes or guidance documents; they latch onto catch phrases and sound bytes. When a supplement brand references “clinical studies,” explains a “mechanism of action,” and anchors itself in familiar categories like liver or heart health, it begins to occupy cognitive real estate that once belonged almost exclusively to prescription medicine.
The distinction between “supports liver function” and “treats liver disease” is legally meaningful -- but psychologically subtle.
Add to this the fact that supplements are sold on Amazon (now right alongside Rx medications), recommended by friends, and promoted by influencers who speak with confidence and certainty. Over time, these signals recalibrate how authority is perceived. An HCP-prescribed therapy and a daily wellness shot may feel different in intensity and effect, but they are not always viewed as fundamentally different in legitimacy.
For patients managing chronic conditions, or those at risk, the supplement often becomes a parallel path rather than an alternative one. And in some cases, a substitute.
One of the most striking disparities between supplement and pharma marketing is not creativity -- it’s constraint.
Supplement brands operate without fair balance requirements, without the need to enumerate adverse events in 60-point font, and without extensive MLR review of promotional materials before they reach consumers. This allows for clarity, narrative flow, and emotional resonance that pharma marketers might envy.
Dose’s communications, for example, read like thoughtful consumer education. They explain why an ingredient is included, how it works in the body, and what the consumer might expect over time. The absence of overt risk language makes the message feel reassuring and approachable, even when the underlying science may be preliminary or associative rather than causal.
This is not to suggest bad faith -- indeed, I am a Dose customer. Many supplement companies are genuinely investing in better science. But, with all of that said, the playing field is uneven; and consumers rarely understand the difference.
For those of us responsible for researching and mapping patient journeys, this evolution demands our attention.
First, supplements are increasingly part of the treatment ecosystem, whether physicians acknowledge them or not. Ignoring them creates blind spots in adherence, outcomes, and patient decision-making.
Second, consumer expectations are being shaped well beyond traditional healthcare channels -- and they are converging around experiences with minimal friction. Consumers are increasingly accustomed to transparency, speed, and direct access to information. Against that backdrop, prescription brands that feel opaque, slow, or overly constrained stand out sharply, even when those constraints are necessary and appropriate.
Third, the definition of “competition” is expanding. For liver and cardiovascular categories in particular, supplements are positioning themselves upstream of diagnosis and alongside maintenance therapy. They may not replace prescription drugs, but they can delay initiation, fragment engagement, or dilute perceived necessity.
There are lessons here, even within regulatory constraints.
Pharma can invest more deeply in explaining, not just stating, its science. Mechanisms of action, disease progression, and therapeutic intent can be communicated with greater narrative coherence, even within fair balance requirements.
There is also an opportunity to evaluate how consumers interpret evidence. Supplement brands have learned to translate complex data into accessible, authentic stories without overwhelming their audience. That translation skill is underutilized in prescription marketing.
Finally, there is a role for education -- not promotion -- around the discrepancies between supplements and prescription therapies. Helping patients understand what “clinically proven” truly means, and why regulatory rigor exists, is not only ethical; it reinforces long-term trust.
The supplement industry is not trying to become pharma. But it is becoming more fluent in pharma’s language: science, credibility, outcomes. And that fluency is resonating with consumers.
For biopharma professionals, this is not a threat so much as a signal. The boundaries between wellness and medicine are becoming more porous, driven by consumer behavior rather than regulatory design.
That shift is already underway. The real question is how those of us responsible for evidence-based health decisions choose to respond.
Because the consumer has already moved on. The question is whether the rest of the industry is paying attention.
