Essential Elements of a Supplement Label
For a dietary supplement to be legally marketed in the United States, its label must include five key pieces of information, as mandated by the FDA. These elements are strategically placed across the principal display panel (PDP) and the information panel (IP).
Principal Display Panel (PDP) Requirements
The PDP must feature:
- Statement of Identity: The name of the product, such as "Vitamin D Supplement," in a prominent font size.
- Net Quantity of Contents: Located within the bottom 30% of the PDP, stating the amount of supplement in the package by weight, measure, or count.
Information Panel (IP) Requirements
The IP, typically to the right of the PDP, must contain the following if not on the front. Formatting must follow specific guidelines.
- Supplement Facts Panel: This panel requires proper formatting and includes serving size, servings per container, dietary ingredients, amount per serving, and % Daily Value.
- Ingredient List: Any ingredients not in the Supplement Facts panel must be listed below it.
- Manufacturer, Packer, or Distributor Information: Name and place of business of the responsible party.
The Role of Regulatory Claims
Supplement labels can include claims, regulated by the FDA and FTC. There are three main types:
- Health Claims: Describe links between a substance and disease, requiring specific FDA approval.
- Nutrient Content Claims: Describe the level of a nutrient (e.g., "high," "low").
- Structure/Function Claims: Describe a nutrient's role in body structure or function. No FDA approval needed, but substantiation is required, and a mandatory FDA disclaimer must be included.
Claims, Disclaimers, and Other Label Elements
Other mandatory statements include:
- The FDA Disclaimer: Required for structure/function claims: "This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease".
- Adverse Event Reporting: Must include a domestic address or phone number for reporting serious adverse events.
- Warning Statements: Essential cautions like "Keep out of reach of children" or allergy warnings.
Comparison: FDA vs. EU Labeling Requirements
Comparing US to EU regulations highlights differences in approach while both prioritize consumer safety.
| Feature | US (FDA) Requirements | EU (e.g., Directive 2002/46/EC) Requirements |
|---|---|---|
| Classification | Dietary supplements are a category of food. | Food supplements are considered foods. |
| Claims Regulation | Health claims need FDA approval; structure/function claims require a disclaimer. | Health claims are regulated under Regulation (EC) No 1924/2006 and must be authorized. |
| Pre-market Approval | Not required, but notification is needed for new dietary ingredients (NDIs). | No pre-market approval, but specific rules apply. |
| Disclaimer | Mandatory disclaimer for structure/function claims, stating product is not intended to "diagnose, treat, cure, or prevent any disease". | No explicit FDA-style disclaimer, but claims cannot be misleading or imply a cure/treatment. |
| Information Language | English is typically required. | Must be in the language of the country of sale. |
| Daily Dose Warning | Implicitly covered in directions; not a specific standalone warning requirement. | Must explicitly warn not to exceed the recommended daily dose. |
Labeling for Proprietary Blends
Specific FDA rules apply to proprietary blends to protect unique formulas while informing consumers.
- Identified as "Proprietary Blend" or similar.
- Total weight of all ingredients in the blend is listed.
- Ingredients listed in descending order by weight.
- Individual ingredient amounts within the blend are not required if the total weight is provided.
Conclusion: The Importance of Compliance
Understanding what is required on a supplement label is vital for consumer safety, trust, and manufacturer compliance. FDA guidelines ensure accurate information on contents, potency, and risks. From identity to the Supplement Facts panel and disclaimers, each element prevents misleading claims and promotes transparency. Non-compliance can result in legal issues, including fines and recalls. Adhering to these guidelines protects businesses and empowers consumers to make informed health decisions.
Food and Drug Administration's Labeling Requirements for Dietary Supplements