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Malcom is a purpose-driven, commercially focused leader with 20+ years of international experience in consumer health. He previously held senior roles at GSK Consumer Health and Haleon, and is now Strategic Advisor at Lindus Health.
Most people do not take OTC and self-care products the way clinical trials imagine. They miss doses, combine remedies, and choose in the pharmacy aisle rather than a doctor’s office. Traditional trials often answer a narrow question: does the product work under ideal conditions? Consumers rarely use OTC and self-care products under such conditions. Regulators and retailers now look beyond efficacy in tightly controlled settings. They want evidence that reflects performance in the real world.
Real-world evidence (RWE) meets this need. By linking consumer-reported outcomes, digital usage logs, and survey inputs, sponsors can generate insights into adherence, safety, satisfaction, and effectiveness at scale. These findings strengthen claim credibility, help refine products, improve labeling, and build trust in competitive OTC and self-care categories.
In today’s crowded OTC and self-care market, consumers are more discerning than ever. An NSF study reported that 95% of Americans had concerns about the quality or safety of supplements, OTCs, and personal care products. Regulators are equally alert. The FTC’s Health Products Compliance Guidance requires competent and reliable scientific evidence. In practice, sponsors cannot rely on vague “clinically tested” phrasing or small, narrowly scoped studies. To earn trust and regulatory acceptance, evidence must show how a product performs in the contexts where it is actually used.
The FDA’s real-world evidence framework adds further expectations. For sponsors in OTC and self-care, “fit for purpose” does not mean pharma-scale datasets. Still, it does mean pre-specified protocols, transparent methods, adequate sample sizes, and robust handling of consumer-reported outcomes. Sponsors should be prepared to explain endpoint selection and how bias was minimized.
Conventional trials show whether a product works under controlled conditions, but that is rarely enough here. Consumers want to know whether it works for people like them, in everyday contexts.
RWE studies fill this gap by showing:
These insights complete the value picture and guide lifecycle management, including formulation, labeling, and target populations. To count as evidence, RWE must meet rigorous standards. Data should be fit for purpose with pre-specified protocols, transparent analyses, and methods to address bias.
Collecting real-world data is only the first step. The greater challenge is turning findings into claims that resonate with consumers and hold up to regulatory scrutiny.
Good practice includes mapping desired claims at the outset and aligning endpoints to those goals, ensuring claim language reflects evidence strength, and using consumer-facing insights such as satisfaction or usability as secondary support. By starting with the claim strategy and designing backward, every dataset connects to a market-relevant outcome. Add a one-line methods note covering design, population, and analysis plan.
For many sponsors, the promise of RWE is clear, but execution is harder. Common barriers include CROs that rely on rigid, pharma-modeled designs, difficulty recruiting large and diverse populations, and complex data flows. In many consumer health companies, studies are under-resourced or treated as side projects rather than strategic initiatives.
These challenges can be addressed with the right design and infrastructure. Unlike pharma, RWE for OTC and self-care must balance cost, speed, and consumer-centric endpoints without compromising integrity. Consumer health CROs succeed with adaptive, decentralized models that combine scientific rigor with real-world applicability. Broad recruitment networks enable enrolment at scale, while digital platforms support compliant eConsent and secure, audit-ready data flows. Dedicated study teams move faster and deliver higher-quality evidence.
The outcome is a study model that balances speed, cost efficiency, and scientific credibility, producing data that is relevant to both regulators and the market.
The future of evidence in consumer health is not about idealized testing, but about showing how products perform in the lives of real people. Well-designed RWE captures adherence, satisfaction, and usage patterns while meeting regulatory standards. It generates claims that consumers can trust and regulators can accept, and it provides insights that improve product lifecycles and strengthen brand credibility.
In a crowded OTC and self-care market where consumer trust is hard won, real-world evidence is not simply a data source. It is a strategic asset that distinguishes products able to demonstrate real-world impact from those that cannot. Brands that invest in credible real-world studies will be best positioned to meet tightening standards, win consumer confidence, and outpace competitors.