Food Supplement Labelling

Written By Bethany Dean

In the bustling world of health and wellness, food supplements have become an integral part of many individuals' daily routines. Whether it's bolstering essential nutrients or supporting specific health goals, the demand for these products continues to soar. However, with this surge in popularity comes a parallel need for stringent regulations to ensure consumer safety and transparency. Have you ever taken a moment to look at the product labelling of the food supplements in your home? Does it vary from brand to brand? Or can you see clear consistency in the wording, messaging and format?

If you're a business owner or entrepreneur venturing into the realm of food supplements in the UK, understanding the intricate web of labelling requirements is paramount. From ingredient listings to health claims, adhering to regulatory standards isn't just about compliance; it's about building trust with your customers and safeguarding the integrity of your brand.

This simple top-line guide provides you with the general labelling requirements for food supplements.

The labelling requirements for food supplement can be separated into three main elements:

  1. Food Supplement (England) Regulation 2003

  2. EU Food Information for Consumers Regulation (EU FIC)

  3. Nutrition & Health Claim Regulation

Food Supplement (England) Regulation 2003:

The main element we will focus on from the Food Supplement Regulations 2003 is section 6:

(1) No person shall sell a food supplement which is ready for delivery to the ultimate consumer or to a catering establishment unless the name under which it is sold is “food supplement”.

Note: Check does your product labelling clearly state “Food supplement” is this detailed on the front on pack, clearly visible to the customer?

(2) Without prejudice to the Food Labelling Regulations 1996(6), no person shall sell a food supplement which is ready for delivery to the ultimate consumer or to a catering establishment unless it is marked or labelled with the following particulars—

(a) the name of the category of any vitamin or mineral or other substance with a nutritional or physiological effect which characterises the product or an indication of the nature of that vitamin or mineral or other substance;

(b) the portion of the product recommended for daily consumption;

(c) a warning not to exceed the stated recommended daily dose;

(d) a statement to the effect that food supplements should not be used as a substitute for a varied diet;

(e) a statement to the effect that the product should be stored out of the reach of young children; and

(f) the amount of any vitamin or mineral or other substance with a nutritional or physiological effect which is present in the product.

Note: Review your product labelling against the above 6 criteria. Do you state them all, do you know what the daily consumption is for the vitamins and minerals in your product, do you have enough of the RDA to be able to make the approved health claim?

If you answer no to some of the above, the below references may help:

EU Food Information for Consumers Regulation (EU FIC):

The Food Supplements (England) Regulations 2003 only details some of the labelling requirements for food supplements, this was recognised in the EU in 2011 and regulators worked together to consolidate many pieces of regulations surrounding the labelling of food supplements into one regulation - EU Food Information for Consumers Regulation (the EU FIC). The EU FIC is directly applicable across the EU, and following the EU Exit, the wider food industry wishes to maintain the regulatory framework in the UK, this was approved as per The Food (Amendment) (EU Exit) Regulations 2019 and amended by The Food (Amendment) (EU Exit) Regulations 2020.

Below detail the addition requirements that can now be added to above detail:

The product label must include:

  • the business name and address, which can be placed either on the product label or product packaging. This must be either:       

(a) the name of the business whose name the food is marketed under; 

or

(b) the address of the business that has imported the food

Food supplements sold in NI must include a NI or EU address for the food business. If the food business is not in NI or EU, they must include the address of the importer, based in NI or the EU. Food businesses can continue to use an EU, GB or NI address for the FBO on food supplements sold in GB until 30 September 2022.

From 1 October 2022, food supplements sold in GB must include a UK, Channel Islands or the Isle of Man address for the food business. If the food business is not in GB, they must include the address of the importer, based in the UK, Channel Islands or the Isle of Man.

  • a list of ingredients, including common allergens which must be emphasised

  • conditions for use, including information on the recommended daily dosage and a warning not to exceed this

  • storage instructions including a statement that the product should be stored out of the reach of young children

  • a ‘use by’ or ‘best before’ date 

  • the amount of any vitamin or mineral or other substance with a nutritional or physiological effect which is present in the product

  • a statement that food supplements should not be used as a substitute for a varied diet

Things now become a bit more complex, and this is without considering N&HC Regulation.

Nutrition & Health Claim Regulation:

European Regulation 1924/2006 on nutrition and health claims made on foods came into force on 19 January 2007 and applied from 1 July 2007. It seeks to protect consumers from misleading or false claims. It also makes it easier for manufacturers to identify nutrition and health claims that can be used on any specific food product.

The Regulation requires that nutrition and health claims made on foods are authorised before being used in Europe; the EU register of authorised claims is on the European Commission’s website. Other key requirements of the Regulation are that:

  • Claims must comply with the general rules which include not being false, ambiguous or misleading; not encouraging or condoning excess consumption of a food; and not implying that a balanced diet cannot provide necessary nutrients.

  • If a claim is made it is it obligatory to provide nutrition labelling in most cases.

  • Only nutrition claims in the EU Register can be made and only if a product meets with the specific conditions of use for that claim. For example, “low fat” can only be made on a product containing no more than 3g of fat / 100g (for a solid) or no more than 1.5g fat / 100ml (for a liquid).

  • Health claims must be authorised and included in the list of authorised health claims in the EU Register before they can be used.

  • With limited exceptions, claims must not be made on alcoholic beverages containing more than 1.2% by volume of alcohol.

  • Health claims which suggest that health could be affected by not consuming a food cannot be made.

  • Health claims which make reference to the rate or amount of weight loss cannot be made.

  • Health claims which make reference to recommendations of individual doctors or health professionals cannot be made on food.

Since the EU Exit there is a list of approved nutrition and health claims for GB, as linked above.

The labelling requirements for food supplement separated into three main elements is detailed above, with some detail on the requirements you must meet on your food supplement labelling. Understanding food supplement labelling is complex and product labelling review should be carried out by qualified personnel to ensure you are compliant and to prevent company headaches! However, the above can you help you understand what you should be expecting on your labelling, enables you to understand the feedback you may receive from a regulatory and help you do an initial draft review.

Taylored Consultancy Ltd can support your company with food supplement labelling review for the UK and EU as above, but also for the US!

Want to ask any confirmation questions, want us to review your label, drop us a note - click the link!

Bethany Dean
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