As early as 1922, the American Medical Association described the hype surrounding these products as "a gigantic fraud." (Bass and Young 1996) Some physicians and nutrition scientists did encourage their patients to obtain nutrients in proper amounts from food rather than pills. However, supplement use continued to grow substantially. By the mid-1930s, the U.S. Food and Drug Administration (FDA) established a Vitamin Division that analyzed the contents of supplements and took action against dishonest vitamin manufacturers and advertisers (Dickinson 1999). .
In 1938, Congress passed the Food Drug and Cosmetic Act (FDCA), which strengthened the original 1906 law. This act also provided more specifics on when a food could be considered contaminated or misbranded so the FDA could take action. Armed with this new law, FDA issued regulations in 1941 for what it termed "foods for special dietary use," a category that included infant formulas, foods for individuals with allergies, protein, and products containing vitamins, minerals, and/or other ingredients intended "to supplement the human diet." (Bass and Young 1996) .
FDA developed quantitative "minimum daily requirements" (MDRs) for individual nutrients, single values that were based on the new Recommended Dietary Allowances (RDAs) established in May 1941 by the Committee on Food and Nutrition of the National Academy of Sciences (Report to the Commission on Dietary Supplement Labels 1997). Supplement makers were required to announce the percent of the MDR of each ingredient on every product label. For nutrients without an MDR, the label had to state that the need for that nutrient was not established. However, no limitations were placed on the variety or amount of nutrients in supplements (Dickinson 1999). .
By using their new powers under the FDCA Act, the FDA brought hundreds of court actions against the dietary supplement industry for what they considered to be false and misleading nutritional claims made in the labeling and promotion of products.
