Nutrition Facts vs. Supplement Facts

by Christine Hronec

 
Products with a “nutrition facts” label are being sold as a food. That means all the additives must be generally regarded as safe or formally approved by the FDA. Such products can be packaged like soft drinks and placed near other beverages, including bottled water and orange juice.

Conventional foods are foods that are not dietary supplements. A dietary supplement is a product taken by mouth that is intended to supplement the diet and that contains one or more “dietary ingredients.” The “dietary ingredients” in these products may include vitamins, minerals, herbs or other botanicals, amino acids, and other substances found in the human diet, such as enzymes. If the product is marketed as a dietary supplement, the ingredients aren’t necessarily reviewed for safety/efficacy by the FDA. They carry a “supplement facts” label and include a disclaimer that reads: “These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure or prevent any disease.”

The major differences between “Supplement Facts” panel and “Nutrition Facts” panel are as follows:

  • You must list dietary ingredients without RDIs or DRVs in the “Supplement Facts” panel for dietary supplements. You are not permitted to list these ingredients in the “Nutrition Facts” panel for foods.
  • You may list the source of a dietary ingredient in the “Supplement Facts” panel for dietary supplements. You cannot list the source of a dietary ingredient in the “Nutrition Facts” panel for foods.
  • You are not required to list the source of a dietary ingredient in the ingredient statement for dietary supplements if it is listed in the “Supplement Facts” panel.
  • You must include the part of the plant from which a dietary ingredient is derived in the “Supplement Facts” panel for dietary supplements. You are not permitted to list the part of a plant in the “Nutrition Facts” panel for foods.
  • You are not permitted to list “zero” amounts of nutrients in the “Supplement Facts” panel for dietary supplements. You are required to list “zero” amounts of nutrients in the “Nutrition Facts” panel for food.

21 CFR 101.36(b)(3) and (b)(2)(i), 21 CFR 101.4(h), 21 CFR 101.36(d) and (d)(1), and 21 CFR 101.9

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