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Supplement Facts vs. Nutrition Facts

Dietary supplements don't use the Nutrition Facts panel — they use Supplement Facts, under different FDA rules. Here is when each applies, how the panels differ, and the claim rules unique to supplements.

Updated June 19, 2026 · 4 min read · Sourced from FDA guidance

Which panel does your product need?

A Nutrition Facts panel (21 CFR 101.9) is for conventional food. A Supplement Facts panel (21 CFR 101.36) is for dietary supplements — products intended to supplement the diet that contain a dietary ingredient (a vitamin, mineral, herb, amino acid, and so on) and come in a form such as a capsule, tablet, softgel, gummy, powder, or liquid not represented as conventional food.

Classification follows how the product is marketed, not just what is in it. A protein bar is usually a conventional food (Nutrition Facts); a protein powder marketed as a dietary supplement uses Supplement Facts. Supplements are regulated under the Dietary Supplement Health and Education Act (DSHEA) of 1994.

How Supplement Facts differs

  • Header — it reads 'Supplement Facts,' not 'Nutrition Facts.'
  • Ingredients with a Daily Value — vitamins and minerals that have an established Daily Value are listed with their amount and %DV, much like on a food label.
  • Ingredients without a Daily Value — botanicals, amino acids, and novel compounds with no established DV are listed (typically below a heavy rule) with a '†' symbol and the footnote 'Daily Value not established.'
  • Botanical source — for a plant ingredient, the part of the plant must be identified (root, leaf, and so on).
  • 'Other ingredients' — fillers, binders, and capsule materials that are not dietary ingredients are listed below the panel, in descending order by weight.

Proprietary blends

A proprietary blend lets a manufacturer group several dietary ingredients under one name without disclosing each one's amount. Under 21 CFR 101.36(c), the blend must be labeled a 'Proprietary Blend' (or a descriptive or fanciful name), show the total weight of the blend per serving, and list its ingredients in descending order by weight — but the individual amounts may be withheld. It is legal, though it means you cannot see how much of each ingredient you are getting.

Claims: structure/function and the DSHEA disclaimer

Supplements commonly carry structure/function claims — statements about how an ingredient affects the body's normal structure or function, such as 'supports immune health' or 'helps maintain healthy joints.' These are allowed without FDA pre-approval, but the manufacturer must hold substantiation, must notify the FDA within 30 days of marketing, and must print the DSHEA disclaimer:

Note

'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.' The disclaimer requirement is 21 CFR 101.93; the FDA explains the claim rules here.

A supplement may not claim to diagnose, treat, cure, or prevent a disease — that would make it an unapproved drug. The line between a structure/function claim and a disease claim is exactly where many supplement labels get into trouble. Conventional-food claim rules are covered in the claims guide.

The rest of a supplement label

Like any packaged product, a supplement also needs a statement of identity (including the words 'dietary supplement'), a net quantity of contents, the Other Ingredients list, allergen information, and the manufacturer's name and address — the same non-panel elements covered in the label-requirements guide. Build a panel with the Supplement Facts generator.

Important

The FDA does not approve dietary supplements before they go to market. The manufacturer is responsible for ensuring the product is safe and the label is truthful and compliant — so getting the panel and claims right is on you, not a reviewer.

Frequently asked questions

When do I use Supplement Facts instead of Nutrition Facts?
Use Supplement Facts (21 CFR 101.36) when the product is a dietary supplement — intended to supplement the diet, containing a dietary ingredient, and sold in a form like a capsule, tablet, gummy, powder, or liquid not presented as conventional food. Conventional foods and beverages use Nutrition Facts.
What does 'Daily Value not established' mean?
It marks a dietary ingredient — usually a botanical, amino acid, or novel compound — for which the FDA has set no Daily Value. The amount is still listed, but with a '†' symbol and the footnote 'Daily Value not established,' because there is no DV to calculate a percentage against.
Are proprietary blends legal?
Yes. A proprietary blend must show the total weight of the blend and list its ingredients in descending order by weight, but individual amounts may be withheld. It is permitted under 21 CFR 101.36(c), though it limits how much you can tell about each ingredient's dose.
What disclaimer do supplements need?
If a supplement makes a structure/function claim, it must carry the DSHEA disclaimer: '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.' The manufacturer must also notify the FDA within 30 days of marketing.
Does the FDA approve supplements before sale?
No. Unlike drugs, dietary supplements do not get FDA pre-market approval. The manufacturer is responsible for the product's safety and for truthful, compliant labeling.

Sources

Related tools & guides

This guide is general educational information, not legal advice, and labeling rules can change. Your obligations depend on your specific products, claims, sales, and state. Verify your situation against the current FDA guidance and eCFR linked above, or consult a qualified food-labeling professional, before printing a label.