Dry Labbing

Dry labbing is the practice of issuing test results — typically in the form of a Certificate of Analysis — without actually performing the analytical work, or falsifying results to produce a desired outcome. In the supplement industry, dry labbing has been documented in FDA warning letters and enforcement actions. The June 2024 FDA warning letter to West Coast Laboratories cited failures to conduct required identity testing and verify test results, demonstrating how the practice manifests in real regulatory action. Dry labbing undermines the entire testing infrastructure: a brand using a dry-labbed COA to demonstrate compliance is unknowingly building on fabricated evidence. The practice is particularly insidious because the output (a professional-looking COA) is indistinguishable from legitimate results without independent verification.