Probiotic Claim

Hello, my company has used the word probiotic in the past (before I got here) on dietary supplements in the past and they are considering using it going forward.  I know we obviously can't make health claims and it has to be structure or function, but it seems to be a fairly murky area in general with the FDA still looking into it.  I was wondering if there was a way to do it without having to do end of shelf life CFU studies if we are not trying to put the amounts of various bacteria on our label.  It is mainly that we use products like apple cider vinegar that are probiotic by nature.  Any feedback is appreciated!

If apple cider vinegar does not contain live cultures, it is not considered to be probiotic containing product.


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