Supplement Fact Panel Guide
Wondering whether to use a supplement or nutrition label? In this comprehensive guide we’ll break down when each type is needed and the major difference between supplement facts and nutrition facts. In either case ReciPal makes creating your label a breeze. If you need to create your own supplement fact panel you can try our free tool:
Defining a Supplement
Supplements are intended to, well, supplement the diet with one of the following:
- A vitamin;
- A mineral;
- An herb or other botanical;
- An amino acid;
- A concentrate, metabolite, constituent, extract, or combination or combination of ingredients described above.
However, the key distinction is what a supplement is not. A supplement is not represented for use as a conventional food or as a sole item of a meal or the diet. Supplements, therefore, often contain very few calories and their main purpose is to increase your nutrient intake. With supplements, it’s less about curbing your hunger or thirst and more about increasing your iron intake.
A food product can have supplements in it, but if that product is intended as a meal then a nutrition fact label is likely the right fit. One way to help make the distinction is by taking a look at your serving size.
If your serving size is a capsule, tablet, gummy or anything that could be described as a “dose” then it’s likely a supplement label is the best fit.
Supplement vs Food Product
While a protein bar may promote its protein content, it’s intended as a conventional food or sole item of a meal which means it falls under nutrition fact label jurisdiction.
Creatine powder, on the other hand, is not intended to be a meal, but to increase muscle performance and would thus use a supplement fact label.
Figuring out which label type is right
While the FDA classifies conventional foods and supplements into different categories, protein powder, for instance, is something that can fall into either category. The manufacturer must choose the best label type based on how they are representing their product - as a conventional food or a supplement. So if its primary purpose is as a dietary supplement then, you guessed it, go with a supplement label.
Identifying the purpose of your product is the easiest way to help determine what type of label is required. However, the product’s purpose is not the only factor. The ingredients used in the product also dictate whether it would be classified as a supplement or considered to be a food product.
GRAS Ingredients
The FDA has a list of ingredients that have been tested and found to be “Generally Regarded as Safe” (GRAS).
Nutrition fact labels can only use GRAS ingredients, whereas supplements are not held to this same standard. Although an ingredient used in a dietary supplement must not adulterate the supplement, it does not have to be GRAS for its intended use in the supplement. Because of the closer scrutiny by the FDA on nutrition labels, manufacturers that have the option of choosing between a nutrition label or a supplement label, may choose the nutrition label as a way to signal a more robust standard of safety.
Disclaimers
Speaking of safety, while supplement manufacturers can make claims about how their product supports health, those claims must be followed by the words, “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.” Further, any claim made on the packaging of your product must be backed up by the information contained in the nutrition or supplement fact label. Therefore, the claims that you’re making can also be a determining factor in the type of label you should use, as each label allows for different information to be displayed (we'll get into that later on).
Now that you’ve got all the information you need to determine the right label for your product, let’s take a deeper look at the differences between the two label types.
How Supplement and Nutrition Fact Labels Differ
The nutrition label for a dietary supplement is called a "Supplement Facts" panel.
To the untrained eye, aside from the panel title, nutrition and supplement labels look strikingly similar. But there are many nuances between the two types that are important to understand.
On supplement panels, dietary ingredients that have Daily Values will be listed in the same order as for the labels of conventional foods, except that vitamins, minerals and electrolytes are grouped together.
Dietary ingredients without Daily Values must be placed after those having Daily Values. These ingredients will be listed by their common name with the weight per serving immediately following it. They must also be marked with a symbol in the column for "% Daily Value" that refers to the footnote "Daily Value Not Established."
Supplement panels can include “Proprietary Blends” where the total weight of the ingredients of the blend is listed followed by the ingredients in descending weight order. One other difference from Nutrition Fact panels is that ingredients in dietary supplements that are not dietary ingredients, such as binders, excipients, fillers, must be included in the ingredient statement.
As always, it’s crucial to remember that anything you make a claim about needs to be represented in the supplement fact label.
We’ve just scratched the surface, but it should be clear that while supplement panels allow for some more flexibility they are still quite complicated to keep compliant. Try out ReciPal’s BETA Supplement label generator for free and let us know what you think!
