No, you cannot simply say that a supplement is “good for your health”. In the European Union, there are strict rules governing what you are allowed to claim about a supplement. Only claims that have been approved on the European list of permitted health claims may be used, and even then only under specific conditions. In this article, we answer the most frequently asked questions about health claims on supplements, so that you know exactly what is and isn’t allowed.
What distinguishes a health claim from a nutrition claim?
A nutrition claim describes a property of a nutrient, such as “rich in vitamin C” or “high in protein”. A health claim establishes a link between an ingredient and an effect on the body, such as “vitamin C contributes to the normal functioning of the immune system”. The difference lies in the relationship you establish: are you describing what is in it, or are you claiming what it does?
This distinction is laid down in European Regulation (EC) No 1924/2006 on nutrition and health claims. Nutrition claims are relatively simpler to use, provided the product meets the relevant threshold values. Health claims are more strictly regulated and must be assessed and approved by the European Food Safety Authority (EFSA) before they may appear on a label or in marketing material.
In short: a nutrition claim relates to the composition, whilst a health claim relates to the effect. The latter category always requires a legal basis.
What claims are legally permitted on supplements?
Only health claims that appear on the approved EU list – also known as the “Article 13” and “Article 14” lists – are permitted on food supplements. These lists contain hundreds of approved statements linked to specific nutrients. Claims not included on these lists simply cannot be used, no matter how well-founded they may seem.
There are three types of health claims that are most commonly found in practice:
- Functional claims (Article 13.1): Describe the role of a nutrient in normal bodily functions. For example: “Magnesium contributes to normal muscle function.”
- Claims based on new scientific findings (Article 13.5): Based on more recent studies, but requiring an individual EFSA assessment.
- Claims regarding the reduction of health risks (Article 14): Claiming that a substance reduces the risk of a disease. These are the most restrictive claims and may only be used if they have been explicitly approved.
In addition to the content of the claim, there are also conditions governing its use. For example, the product must contain a significant amount of the nutrient in question, and the claim must be accompanied by mandatory additional information, such as the recommended daily intake.
Why is saying ‘it’s good for your health’ risky?
The phrase “good for your health” is what is known as a general health claim and is prohibited in the EU without specific supporting evidence. Such vague claims give the impression that a product has a broad positive effect on health, without this being specified in concrete terms. The legislator regards this as misleading to consumers.
The risk for brands and manufacturers is considerable. The Netherlands Food and Consumer Product Safety Authority (NVWA) actively monitors claims made on labels and in online marketing. In the event of a breach, fines may be imposed, but a mandatory product recall or a ban on further sales is also possible. Damage to a brand’s reputation can then have a greater impact than the fine itself.
Furthermore, the ban does not apply solely to the physical label. Statements on social media, in adverts, on websites and in product descriptions are also subject to the same regulations. A supplement that is correctly labelled on its packaging may still be in breach if the accompanying Instagram post contains prohibited claims.
How do you phrase claims that are actually permitted?
The key is always to start with the approved EU list and use the exact wording or wording that is very closely aligned with it. Do not change any words that might alter the meaning, and link each claim to the correct nutrient and dosage. This way, you remain within the legal framework whilst still communicating effectively.
Practical guidelines for formulating claims correctly:
- Use the exact wording of the EU list, or a translation that is equivalent in substance.
- Always specify the particular nutrient to which the claim relates, not the product as a whole.
- State the daily amount required to achieve the claimed effect.
- Where appropriate, include a disclaimer such as “as part of a varied diet and a healthy lifestyle.”
- Avoid using words such as “cures”, “treats”, “prevents” or “helps with” in conjunction with the names of diseases, unless this has been explicitly approved as an Article 14 claim.
A good example of a correct claim is: “Zinc contributes to the normal functioning of the immune system.” This is an approved statement, linked to a specific substance, and says nothing about the product as a whole.
What does this mean for private-label supplements?
Private-label supplements are subject to exactly the same rules as any other supplement on the European market. As the brand owner, you are responsible for the claims on your label, even if production is outsourced to a third party. A manufacturing partner may offer advice, but the legal responsibility for the label content lies with the brand that places the product on the market.
This makes a thorough label check and a food safety plan essential for anyone launching their own range of supplements. Without this foundation, you run the risk of products being rejected, recalled or subject to fines before they have even properly reached the market.
Key considerations for private-label brands:
- Ensure that every claim on the label can be traced back to an approved EU claim.
- Please also check all marketing materials, not just the physical label.
- Set out the arrangements regarding liability for claims in a contract with your production partner.
- Implement a food safety plan that also covers label compliance.
How MixMasters helps with health claims and label compliance
We understand that the regulations surrounding health claims can be complex and sometimes overwhelming, especially when you’re launching your own range of supplements for the first time. That’s why, as a full-service manufacturing partner, we offer support that goes beyond simply manufacturing your supplement.
What we do for you in the areas of compliance and labelling:
- Drawing up an HACCP-based food safety plan that is specifically tailored to your product range.
- Support in ensuring that product information on the label is accurate, including advice on permitted claims.
- Support from our quality team, which works in collaboration with specialist consultants in the field of food safety and regulations.
- Manufactured in a BRCGS-certified facility, which ensures that processes are controlled, traceable and auditable.
- Optional support with label design and print coordination, to ensure the end result is visually striking.
Whether you’re an established brand looking for a reliable manufacturing partner, or an ambitious entrepreneur keen to launch your first range: we’ll ensure you enter the market in full compliance. Take a look our services for a complete overview, or Please contact us directly for a no-obligation chat.
Frequently Asked Questions
Do the EU regulations on health claims also apply to claims on my website and social media?
Yes, the rules set out in Regulation (EC) No 1924/2006 apply to all commercial communications, including your website, social media, adverts and newsletters. It does not matter which channel you use to communicate the claim: if a message is intended to promote a product, it is subject to the same legislation as the physical label. This means that even an Instagram post by an influencer promoting your product must comply with the rules, for which you, as the brand owner, are responsible.
What if an ingredient in my supplement does not have an approved EU health claim?
If an ingredient does not have an approved claim on the EU list, you simply cannot use a health claim for that ingredient, regardless of how much scientific evidence is available. You may, however, list the ingredient in the ingredients list or as a nutrient in the nutrition facts table, but any implication of a health benefit is then prohibited. If you still wish to substantiate a claim for a new ingredient, an Article 13(5) or Article 14 application to EFSA is the only legal route, which is a time-consuming and costly process.
How do I know if my product contains enough of a nutrient to be allowed to make a claim?
Voor elke goedgekeurde gezondheidsclaim gelden zogenaamde ‘conditions of use’, oftewel gebruiksvoorwaarden die bepalen hoeveel van een voedingsstof het product per dagelijkse portie moet bevatten. Deze voorwaarden staan vermeld in de EU-claimregistratie zelf en zijn raadpleegbaar via de EFSA-database of de EU Register on Nutrition and Health Claims. Als je product niet aan de minimumhoeveelheid voldoet, mag je de bijbehorende claim niet gebruiken, ook al staat de stof wel in het product.
Can I post customer reviews containing health claims on my product page?
This is a grey area that many brands underestimate. If, as a brand owner, you actively publish or highlight a review in which a consumer makes prohibited health claims, this may be seen as indirectly using those claims. The NVWA assesses the overall impression a product page conveys, not just the text you have written yourself. It is therefore advisable to moderate reviews for prohibited claims and to make it clear in your review policy which statements you cannot publish.
What are the most common mistakes brands make when labelling supplements?
De meest gemaakte fouten zijn: het gebruik van vage, algemene claims zoals ‘ondersteunt je gezondheid’ of ‘voor meer energie’, het koppelen van een claim aan het product in plaats van aan een specifieke voedingsstof, en het weglaten van verplichte aanvullende informatie zoals de aanbevolen dagelijkse hoeveelheid. Ook het letterlijk vertalen van claims uit niet-EU-markten, zoals de VS, is een veelvoorkomende valkuil, omdat de Amerikaanse FDA-regelgeving fundamenteel verschilt van de Europese. Een grondige labelcheck door een specialist voordat je naar de drukker gaat, voorkomt kostbare aanpassingen achteraf.
As a start-up, how do I go about setting up a compliant range of supplements?
The best approach is not to add compliance as an afterthought, but to treat it as an integral part of your product development from the outset. Start by identifying which ingredients and associated approved claims align with your brand positioning, and then build your formula and label around them. Work with a manufacturing partner who has experience with EU regulations and labelling compliance, and ensure you have a food safety plan in place before launch. This will prevent you from having to reformulate or relabelling products later on, which costs both time and money.
Can I use a claim that is scientifically well-founded but is not included on the EU list?
No, scientific evidence alone is not sufficient under EU regulations. Only claims that have been assessed by EFSA and formally approved may be used. The fact that there are published studies demonstrating an effect does not give you a legal right to communicate that claim on a label or in marketing. If you still wish to introduce a new claim to the market, you must submit an official application via the Article 13(5) or Article 14 procedure, under which EFSA itself assesses the scientific evidence.
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