Nutritional Supplement
Position Statement

Contents
Introduction.......................................................................................................... 2
Legislation & WADA Code .................................................................................... 4
Food First but Not Always Food Only ................................................................... 6
Fortified and Functional Foods v. Supplements ................................................... 9
Understanding “Batch-Testing” and Risk Minimisation Programmes ............... 12
Practical Advice .................................................................................................. 15
Further Reading .................................................................................................. 18

Version:December 2022
Working Group:
Richard Chessor, Julia Bone, Mike Naylor, Louise Sutton, Kathryn Brown, Graeme Close,
Irene Riach & Sharon Madigan1Introduction
Research indicates the use of nutritional supplements is commonplace amongst elite
athletes. Analysis from the FIFA 2006 World cup stated 57% of players reported using
supplements (Tscholl et al. 2008). One study stated that 85% of elite track and field athletes
use supplements (Maughan et al. 2007) and at the London 2012 Olympics, 82% of Japanese
athletes reported using supplements in the year before the games (Sato et al. 2015). Morerecently, 64% of Spanish athletes reported using at least one supplement (Baltazar-Martins etal. 2019), while 97% of Dutch athletes have used supplements at least once in their career(Wardenaar et al. 2018). These data suggest that the majority of elite athletes use
supplements and it is therefore necessary to ensure that the staff supporting them are
sufficiently educated in the efficacy and management of nutritional supplement use.
To protect the rights of athletes to participate in doping free sport, British athletes aregoverned by UK anti-doping rules which are administered by the UK Anti-Doping Association(UKAD). UKAD is responsible for ensuring sports bodies in the UK are compliant with theWorld Anti-Doping Code through implementation and management of the UK’s Anti-Doping
Policy. An important principle of the code is Strict Liability, which means that athletes aresolely responsible for any prohibited substances in their system, regardless of how it got
there and if there was an intention to cheat. The principle of Strict Liability is particularly
relevant where nutritional supplements are concerned, as the risk of inadvertently
consuming prohibited substances is higher compared with consuming food.
Research suggests that the rate of contamination with WADA prohibited substances within
supplements available to purchase in the UK, Europe and USA is between 12 and 58%(Martinez-Sanz et al. 2017). Presence of banned substances was detected in 19% ofsupplements in Australia (LGC, 2016). Meanwhile in the UK 21 of 28 “pre-workout” and “fatburning” supplements were shown to contain banned substances (LGC, 2021).
Parallel to this, nutritional supplements are often initially reported by athletes as the cause of
inadvertent doping. However, this needs careful consideration as the argument may be usedby the innocent and guilty. Recent analysis suggests a range from 6.4-19% of positive doping
cases were due to prohibited substance consumption via a nutritional supplement(s).
(Outram et al. 2015, Lauritzen 2022).
Taken together (the prevalence of nutritional supplement use, the rate of contamination andthe number of positive tests attributed to supplement consumption), this highlights the needfor support staff and athletes to understand the efficacy and safety of the products being
consumed.
The decreased risk of inadvertent doping is one of the reasons that a food first ethos is widely
promoted by Performance Nutritionists. A strong nutrition foundation based on the
consumption of a wide variety of foods can often meet an athlete’s macro and micronutrient
requirements. Furthermore, athletes also benefit from the other nutrients and nutrientinteractions that food contains which may be diluted or filtered out in a supplement form.

2However, we acknowledge that food first does not mean food only, and when usedeffectively and safely, some supplements may contribute towards improvements in healthand/or performance. Typically, supplement use by athletes falls into one of four categories;
to prevent or treat nutrient deficiencies, to provide a practical form of energy and nutrients,
to directly improve sports performance or to indirectly improve sports performance.
However, due to the nature of the supplement industry, there are potential risks, which maylead to an anti-doping violation, such as inconsistencies in production standards or poorsourcing of ingredients. The result being that some products available for everyday purchase
may contain prohibited substances which could subsequently lead to an Anti-Doping Rule
Violation (ADRV).

PurposeThe aim of this position statement is to provide Performance Nutritionists (PN) and otherAthlete Support Personnel (ASP) with a guide to appropriately assess the need forsupplementation and reduce the risk of an ADRV. It will provide the practical guidelines andtools to support athletes, PN and ASP.
This document should be read in conjunction with the SENR Clean Sport Commitment
Statement.

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Legislation & WADA CodeWADA Athletes & Support Personnel
UKAD Athlete Support Personnel Hub
All ASP need to know the essential anti-doping practices and tools available, to help ensure
athletes remain clean. ASP are encouraged to use their influence positively, help develop
ethical behaviour, strong values and foster anti-doping attitudes amongst the athletes thatthey work with.
PN’s registered by SENR in the UK must annually complete the UKAD Introduction to Clean
Sport e-learning module as a requirement of their registration.
The World Anti-Doping Code states the roles and responsibilities that ASP have in relation toanti-doping.
This means you must:• Know and comply with the Anti-Doping Rules, policies and practices that apply to you
as well as those that apply to the athletes you support• Co-operate with the testing programme for athletes• Use your influence on athletes positively to foster clean sport values and behaviours• Tell UKAD and your International Federation if you have committed an ADRV in thelast 10 years• Co-operate with any doping investigation when asked to do so• Not use or possess any prohibited substance or prohibited method without a valid
and justifiable reason• Take the opportunity to be educated on anti-doping matters either through UKAD,
your National Governing Body, Sports Institution or Professional Association• Have conversations within your sporting environment on anti-doping and encourage
regular engagement in clean sport activities and events• Familiarise yourself with the universal rights available to athletes within anti-doping,which are set out in the WADA Athletes’ Anti-Doping Rights Act
What this means for ASP:
Anti-doping is complex and needs attention from all who are bound by the Anti-Doping Rules.
ASP could face a ban from sport, not just athletes. This in most cases is career ending.
Take your responsibilities towards anti-doping seriously and help those around you do thesame.
There is no sympathy for ignorance or carelessness in anti-doping. If an athlete tests positive
for a prohibited substance, it will be for them to prove how the banned substance entered
their system. The Code makes a provision for contaminated products (supplements), soathletes are advised to make sure they can prove that they have taken all reasonable steps tomanage the risks associated with supplement use.
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Thus, whilst the legal responsibility falls to the athlete themselves, a key role of the ASP is toensure that comprehensive and up to date advice is provided to the athlete and the wider
support team. It is therefore imperative that the ASP is up to date with everything they needto know to protect themselves and their athletes.

PRACTITIONER SUMMARY POINTS:
o ASP must remain up-to-date with National and International Anti-Doping education and
expectationso ASP must not only provide the best possible support and care to their athlete, but also
protect themselves and their employer through anti-doping education and actionso ASP are not impervious to bans and ignorance is not an excuseo Honesty and transparency are valued by anti-doping agencies – the ASP can play a largepart in this through their advice and actions.

5Food First but Not Always Food Only
As highlighted above, it is recognised that nutritional supplements carry a risk of inadvertent
consumption of prohibited substances. Typically, this risk presents through four different
sources:• The product contains a prohibited substance (whether listed on the ingredient label
or not)• The product lists a prohibited substance on the ingredient label under a different
name• The product has been contaminated during the manufacturing process• The product is a counterfeit product and does not contain the ingredients stated on
the label
Therefore, in order to minimise risk, the role of the PN is to consider the strategic use of
appropriate nutritional supplements. Adopting a ‘Performance Backwards’ approach byaddressing specific performance and/or health questions empowers strategies to be relevant,specific and individualised. It is proposed that the most suitable personnel to advise on
nutritional supplement use are those registered with an appropriate accreditation body (e.g.
SENR). Such practitioners have had to demonstrate an understanding of appropriate
supplement usage and safety as part of their registration process and be up to date with
relevant ASP UKAD training.
Recently the term “Food first, not food only” (FFNFO) has been proposed by Close (2021).
The term represents a positive movement away from the commonly used but restrictive term
“Food First” with regards to prioritising the consumption of food over nutritional
supplements.
The authors suggest six reasons why a food only approach may not be optimal for athletes:
1. Some nutrients are difficult to obtain in sufficient quantities in the diet, or may
require excessive energy intake and/or consumption of other nutrients
2. Some nutrients are abundant only in foods athletes do not eat or like
3. The nutrient content of some foods with established ergogenic benefits is highlyvariable
4. Concentrated doses of some nutrients are required to correct deficiencies and/or
promote immune tolerance
5. Some foods may be difficult to consume immediately before, during or immediately
after exercise
6. Batch-tested supplements could help where there are concerns about food hygieneor contamination.
Acknowledging that a food first approach may be the preferred strategy to minimise
inadvertent consumption of banned substances, it should also be stated that there are6occasions when a food only approach could be detrimental to the athlete’s health or
performance.
Whilst there remains no universally accepted definition of a nutritional supplement, the mostwidely accepted definition has been proposed by Maughan (2018):“A food, food component, nutrient, or non-food compound that is purposefully
ingested in addition to the habitually consumed diet with the aim of achieving a
specific health and/or performance benefit”
Using this definition and the FFNFO approach, the following decision tree model has been
proposed to help PN and ASP make decisions on appropriate strategic and safe use ofnutritional supplements.

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The PN will play a critical role in supporting the athlete through this decision making process.
SENR practitioners are reminded that they should maintain suitable records of suchdiscussions and recommendations.

PRACTITIONER SUMMARY POINTS:o By understanding the sources of supplement risk the ASP can better incorporate strategies
to minimise this risko A Performance Backwards approach can be used to understand and rationalise thepotential use for nutritional supplementso The FFNFO model proposes scenarios which the ASP can incorporate into the Performance
Backwards approach to help consider the strategic and evidence-informed approach tonutritional supplement use.

8Fortified and Functional Foods v. Supplements
Food fortification involves the addition of vitamins and minerals to foods as part ofmanufacture or processing. In some cases it is required by law, in others it is voluntary. It
can play an important part in improving the micronutrient intake of a population as a whole.
In the UK, food fortification has been commonplace for many years, such as the fortificationof white flour with calcium, iron, thiamine and niacin, or more recently with the fortificationof calcium and iodine in plant-based milk-alternatives.
However, recently, food fortification has grown to incorporate an increase in the demand for‘functional foods’, a very broad range of products which deliver additional or enhanced
benefits over and above their basic nutritional value. Functional foods can be similar to
everyday foods such as yoghurts or low-fat spreads but with added functional ingredientssuch as probiotics or stanols/sterols. Within a sports nutrition context, functional foods areoften marketed as containing extra protein or key vitamins and minerals. Rarely is thismarket driven by athletic performance but instead by general health or beauty.
There is value in having a clear definition of a nutritional supplement because it allows forclarification in identifying which products are considered nutritional supplements and which
are fortified or functional foods. This clarification then allows the PN/ASP to identify if the
product is expected to undergo further testing for the presence of banned substances (e.g.
batch-testing).
As noted above, the current favoured definition of a nutritional supplement comes fromMaughan (2018):“A food, food component, nutrient, or non-food compound that is purposefully
ingested in addition to the habitually consumed diet with the aim of achieving a
specific health and/or performance benefit”
The first part of the definition, “food, food component, nutrient, or non-food compound”, isopen-ended and thus provides little clarity in identifying if a product is a supplement or not.
The latter part of the definition refers to “purposefully ingested”, “in addition” and “specifichealth and/or performance benefit”. These elements indicate that a supplement is consumed
with clear and direct intention which helps us to differentiate the supplement from thehabitually consumed diet.
Therefore, we propose the following considerations to help clarify if a product should be
identified as a nutritional supplement:•

Intent - Is it intentionally consumed for a specific health and/or performance benefit
and not part of the routine habitual diet?
o E.g. purposefully consumed for a specific reason
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•

•

•

o Supplement Example: Creatine Monohydrate
Ingredients – Does the product contain a concentrated source of ingredients whichhave been incorporated for a specific health and/or performance benefit?
o E.g. single nutrient product, multiple nutrient product of concentrated sourceso Supplement Example: Protein powder
Manufacturing – Is the product manufactured at a site or by a company which
produces nutritional supplements and its form does not represent a food product?
o E.g. the product is a encapsulated or powderedo Supplement Example: Multivitamin
Marketing - Does the product make specific claims about health and/or performance
benefits? Is there guidance on the products intended use?
o E.g. claims for improved athletic performance, dosage guidanceo Supplement Example: Caffeine tablets

If the answers to the above considerations are predominantly yes then the product should beconsidered a nutritional supplement and therefore subject to further banned substancetesting.
If the answers are no, it is unlikely that the product is a nutritional supplement and more
likely to be defined as a food, fortified food or functional food and therefore should not
automatically be considered necessary for further testing.
The PN/ASP are urged to use their clinical reasoning and judgement when navigating these
considerations.
Fundamental to the considerations above is an understanding of the manufacturing
processes a product has undergone and the risks associated with this. As noted earlier, a risk
with nutritional supplements is contamination with prohibited substances during
manufacturing. This is because few nutritional supplement companies will manufacture theirown products, instead they outsource to large contract manufacturers who may also produce
multiple products for non-athletic populations containing a wide variety of ingredients,
including potentially WADA prohibited substances. In this circumstance, the nutritional
supplement may become contaminated with a prohibited substance which is part of theformulation of an entirely different product aimed at an entirely different market.
In contrast, food production facilities have no reason for prohibited substances to be present
on their site and food products are subject to rigorous quality control and assurance checks
throughout the manufacturing process with regulatory standards pre-release to market.
Therefore, risk of contamination in food manufacturing sites is significantly reduced.
ASP and PN should also be aware of vendors utilising nutritional supplements in fresh or
made-to-order foods. For example, the inclusion of protein powder in a protein ball/cake in acafe or the use of botanical ingredients such as Maca powder in a fresh juice or smoothie. In
such environments, the athlete and ASP are encouraged to enquire about the source of key
ingredients to help inform decision making. It is noted that most vendors will likely use a10

consumer final product nutritional supplement for their products (i.e. not a raw ingredient as
would be utilised in the food manufacturing industry) and may be unaware of the ADRV risk
associated with their practices

PRACTITIONER SUMMARY POINTS:
o It is recognised that the boundaries between food and nutritional supplements can beblurred and that current legislation makes it challenging to classify ‘borderline’ productso ASP are encouraged to carefully apply the adopted definition of a supplement andconsiderations when helping athletes make decisions in this areao Maintaining suitable records and justifying decision making is an important component oftransparency and risk minimisationo Where there is a choice between similar batch-tested and non-batch-tested products thenASP should always look to promote the batch-tested producto Caution is advised when athletes are faced with products in cafes which may incorporate
nutritional supplements into their fresh and made-to-order foods.

11Understanding “Batch-Testing” and Risk Minimisation Programmes
Nutritional supplements are commonly produced in large batches (or production units) witheach batch given a unique code. “Batch-testing” is a term which refers to the screening of asample from a batch for the presence of prohibited substances.
As a minimum, batch-testing should be undertaken on the final product intended for the
consumer. Therefore, it is separate to any individual ingredient traceability or certificates ofanalysis. The batch-testing process does not exist to quantify the levels of ingredients withina product nor review product efficacy, it simply highlights the presence of banned substances
as listed in the WADA Prohibited List. Testing is undertaken by accredited laboratories withextensive ingredient analytic capabilities and are independent from any anti-doping
authorities. The supplement manufacturer pays the laboratory for this process and often will
use the results to market their products towards elite athletes and those subject to the
WADA code. The unique codes for each tested batch are often published on the
manufacturer or batch-testing company’s website – this allows the consumer to cross-checkthe code on their product with those listed on the register.
Central to the Supplement Use Decision Matrix is the requirement that all supplements arebatch tested by a known third party laboratory. As such, recommending products which havenot been batch tested goes against these best practice guidelines.
Numerous companies provide batch-testing services with five common programmes
highlighted below. It is important to understand and research the process and standards
involved with each of these companies as differences do exist which may impact decision
making. Furthermore, different National Anti-Doping Agencies and Governing Bodies
recognise different testing programmes, thus the ASP must be aware of the legislation
applicable to their athlete.

Informed Sport (LGC), UK
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•

•
•

4-stage process for certification involving; Product and manufacturing review, Precertification sample testing, Product certification, logo use and web listing, Postcertification requirements and testing.
Requires every product batch (including all flavour variants) to be tested before
release to the marketplace. Regular blind testing of final products purchased on the
open market is also undertaken.
Tested products branded with the Informed-Sport logo are listed on their website andapp.
Note that there is a difference between the Informed-Sport and Informed-Choiceprogrammes. Whilst both use the same testing procedures, the frequency of testing
through Informed-Choice is lesser as it operates through monthly blind sampling.

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National Sanitation Foundation (NSF), USA•••

Assesses products and ingredients for the presence of contaminants that impact
health and substances banned by major sporting organisations. In addition, NSF also
evaluates the composition of nutritional supplements and ingredients to verify the
products contents.
The Certified for Sport programme is the only independent, third-party certification
programme recognised by the United States Anti-Doping Agency (USADA).
Certified products are listed on the NSF database and app.

Banned Substance Control Group (BSCG), USA•••

Offers an array of services for different users. “Certified Drug Free” seal indicates thebatch has been tested for the presence of WADA prohibited substances as well asover the counter and illicit drugs.
Lists certified products on their website database.
Note that other BSCG services may only audit product label claims and/or
manufacturing compliance so check the level of certification you require.

Cologne List, Germany•••

Analyses products for selected anabolic-androgenic steroids and stimulants (thecontaminants which are most often found in nutritional supplements).
Prior to analysis a label quality control check is undertaken.
Approved products are listed on their website and app.

Human and Supplement Testing Australia (HASTA), Australia••

Batch tests for a comprehensive range of WADA prohibited substances, developed
specifically for the Australian market.
Approved products are listed on their website.

Further to these differences between batch-testing services, the supplement manufacturer
may not choose to batch-test every batch or product within their portfolio. Therefore, it isimperative that the ASP or PN discussing supplement use with an athlete checks the final
product and does not assume that a product tested once will remain tested in the future.
It should be clear that batch-testing is not a 100% guarantee that a product is free ofcontamination. The batch-testing process takes a sample from a batch for analysis, it
assumes that any contaminants are equally distributed throughout the batch and present inlevels detectable by their laboratory. Furthermore, no organisation can test for every
substance on the WADA Prohibited List, this is because some substances cannot be tested for(e.g. S0 Non-Approved Substances or insufficient detection technology).
Ultimately, nobody will ever test the portion that is consumed by the athlete. Therefore,
these programmes must be viewed as risk minimisation rather than risk elimination schemes.
13PRACTITIONER SUMMARY POINTS:
o Batch-testing programmes primarily exist to highlight the presence of prohibited
substances – they are not a marker of product efficacy or quality, ASP must undertake
their own research on product efficacy
o The Supplement Use Decision Matrix highlights the need for products which have been
suitably batch-testedo Each testing programme operates differently so ASP must be aware of how this may
affect supplement use decision makingo Batch-testing programmes are risk minimisation schemes.

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Practical Advice
Recognising that athletes will seek advice on supplements, ASP should take caution whenoffering advice, taking steps to protect athletes and themselves. SENR registrants should beconsidered a vehicle of information given their understanding and practical experience in thisfield.
If after careful consideration (incorporating the decision tree above) the athlete wishes touse a nutritional supplement the following points should be considered:

ASP Responsibility:
•
•
•

•
•
•

•
•
•
•

•

Is the athlete suitably ready to use the product?
o E.g. Age, experience, compatibility with health/performance goals
Is the product practical to use?
o E.g. Availability, affordability, tolerance, practicality in training / competition
Provide evidence of the performance or health benefits of the producto E.g. Best available published researcho If published research is lacking specificity to the athlete then consider
collecting evidence through a case study or research projectBe aware of and discuss any adverse effects of the productConsideration should be made for when the product is used in isolation or
conjunction with other products and/or medication
Reinforce the importance of using only batch-tested products. Highlighting that these
are risk minimisation programmes which cannot provide a guarantee that a product isfree of prohibited substances.
Advise the athlete (and support where required) to check final product batch
numbers correspond to those listed on the appropriate register/certificates and not
to rely solely on logos for assurance.
Ensure the athlete is sufficiently knowledgeable about the appropriate protocols to
use the product and place boundaries in and around the products use. For someproducts personalised doses or protocols may need to be established.
Advise that any products should be trialled in training that mimics competition prior
to use in a competition setting. Repeated trials are advised.
Make a record of the discussion that was had with the athlete regarding supplement
use and actions arising.
o This could form part of their defence should an ADRV occur.
o SENR recommends records are kept for a minimum of 10 years in line withretrospective anti-doping testing protocols.
o Refer to the SENR guidance on Record Keeping.
Consider the use of a disclaimer with athletes to ensure that “strict liability” is fully
understood by the athlete.

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Athletes’ Responsibility (to be encouraged by the ASP):• The athlete should keep a record of any research carried out prior to using the
supplemento E.g. Internet research around supplement efficacy
o E.g. Checking the product is part of a batch-testing risk minimisation scheme• Check final product batch numbers correspond to those listed on the appropriate
register/certificates.
• The athlete should keep the batch testing certificate as a paper or electronic copy forat least 10 years.
• The athlete should consider retaining a sample of the product. Bearing in mind that
retrospective anti-doping testing of blood or urine can be carried out for a period of
up to 10 years post collection.

Additional Responsibilities if ASP is Working with a Nutrition Partner (or directly
providing or handling supplements):
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•

•

•

•

Reinforce the principles of strict liability and remind athletes that before taking any
product they must assess the need, risk and consequences of supplement use.
Nutrition partners should be assessed based on product efficacy, good manufacturing
practice (GMP) and quality assurance. Nutrition partners should be able to:o Provide information on quality and traceability of ingredients / products;
o Highlight safety controls and audit frequency; ando Batch-test final products for prohibited substances through a recognised thirdparty programme and provide full certification and transparency of thisprocess
Batch testing certificates must be obtained and stored for any product provided andshould be checked that the batch number of the product corresponds to the batch
testing certificate.
o Batch testing certificates should be stored as a paper or electronic copy for atleast 10 years.
A product database may be useful to set up to manage products supplied through anutrition partner.
o Example information to be stored: product name, flavour, batch number, packsize, expiry dateo PN’s working with a nutrition partner should be expected to provide strong
records of products being handled by them and/or the organisation
Products should be stored in a controlled access location with consideration for
HACCP storage guidanceo Secured lockable location with controlled access and not accessible to the
publico Products should be stored in their original packaging whenever possibleo Inspected upon receipt for damage or tamperingo Not left accessible whilst unattended for extended periods of time orovernight
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o Regular stock checks•••

Products no longer suitable for use should be disposed of appropriately
o E.g. Outdoor bin which minimises chances of the product re-entering
circulation and avoids rodent attention.
When distributing products directly to athletes, the ASP should keep detailed records
including:o Date of provisiono Product provided along with details on flavour, dose/pack size and batch
numbero Any advice provided regarding usageo Provide or signpost towards the relevant batch-testing certification.
When transporting products between sites, the ASP should consider:o Recording details of which products have been moved from their secure
locationo Transport products in original sealed packaging whenever possibleo Transport in appropriate containers to avoid spoilage, damage orcontaminationo Ensure products are in locked containers whilst left unattended (e.g. air travel)

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Further Reading
Maughan et al (2018) IOC consensus statement: dietary supplements and the highperformance athlete https://pubmed.ncbi.nlm.nih.gov/29589768/
Close et al (2021) “Food First but Not Always Food Only” Recommendations for Using Dietary
Supplements in Sport https://pubmed.ncbi.nlm.nih.gov/35279015/
2021 SENR Record Keeping Guidance https://www.bda.uk.com/uploads/assets/bc5edaf128b7-45f8-a232eb9607148735/a76fdb92-4cb4-4536-a2de5fdfef8010ae/SENR-RecordKeeping-2021-final.pdf
2015 HASTA report on supplement contamination frequency in Australia
https://hasta.org.au/wp-content/uploads/2017/10/hasta-survey-of-supps-in-aus_oct15.pdf
2015 report from Anti-Doping Authority Netherlands in collaboration with LGC which
identified the prevalence of banned substances in non-batch-tested nutritional supplements
https://www.dopingautoriteit.nl/media/files/2015/Upper_limit_of_the_doping_risk_linked_to_sports_supplements_20151120_DEF.pdf

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