Resources PrivateLabelSupplements.co.uk

Food Supplement Labelling

Getting Your Food Supplement Label Right (and legal!)

Are your supplement labels fully compliant with the latest UK/EU regulations?
About to launch a new supplement and need guidance on what you can and cannot have on your label?

It can be confusing when putting together a food supplement label. Many people look at what their competitors are doing and just think it is okay to copy them. Unfortunately, you might be copying someone else's mistakes, and then get a visit from Trading Standards for non-compliance to the latest regulations.

What are the latest regulations?

The government kindly has some downloadable factsheets here:

Food supplements: guidance and FAQs
https://www.gov.uk/government/publications/food-supplements-guidance-and-faqs

In summary, here are the highlights:

No health claims - (Unless approved)
That's right, you cannot make any "unapproved" health claims. The reason is that if you do, you are implying that your product is acting as a medicine - which it is plainly not - it is a food supplement.

What claims can you make? Here you go:
EU Nutrition and Health Claims Guidance
http://ec.europa.eu/food/safety/labelling_nutrition/claims/index_en.htm
and for the actual list, here:
http://ec.europa.eu/nuhclaims/
On that page, change the dropdown under "claim status" to "Authorised" and you'll have a list of health claims you can use for which ingredients.

Simply, if there is no authorised claim for the ingredient/s you want to use ... you cannot make any.

What you have to have on your label:

  1. The term "Food Supplement".

  2. Ingredients in weight descending order under the heading "Product Information".
    Ingredients should also be listed with their scientific name, so for example Vitamin D3, (Cholecalciferol).
    And where you have the "other ingredients" list after the main active ingredients, you need to list their purpose, so for example "Brown Rice Flour (bulking agent), Magnesium Stearate (Flowing agent)".

  3. Your company name and address.

  4. Either the best before date on the label, or if it is stamped on the base/top of the bottle, a statement such as "for best before date see base of bottle".

  5. %NRV Colum. RDA’s (Recommended daily intake) have now changed to NRV’s (Nutrient Reference Values). Instead of 100% RDA, you will now see 100% NRV. The values for RDA and NRV’s are the same. You can find a hepful list here (new window will open). So for example you will have the active ingredient name, followed by the mg, followed by the NRV% where applicable.

  6. An allergen warning statement. Most common is the statement "For allergens please see ingredients in bold", where the ingredients that are classed as potential allergens in the supplement ingredients list are printed in a bold typeface.
    Here is some more info from food standards:
    https://www.food.gov.uk/science/allergy-intolerance/label/labelling-changes
    You will also want to check with your manufacturer whether they make products that have allergens, in which case you will want to add a statement such as "Made in a factory that also handles xxx". More info here:
    https://www.food.gov.uk/science/allergy-intolerance/label

  7. Where the product has been manufactured, "manufactured for us in the UK" for example.

  8. Dosage instructions.

  9. Cautions. Warnings on who should not take the product. You should include these:
    Not a substitute for a varied and healthy diet.
    Not intended for use by persons under the age of 18 years (if it is not a specific children's product).
    Do not exceed the stated dose.
    If under medical supervision, consult a doctor before use.
    Store in a cool dark place away from moisture and direct sunlight.
    Keep out of reach of children.

  10. Do not have text in too small a font size. This is a bit complicated, so see page 13 of this UK Government PDF:
    https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207842/2013-06-19_Nutrition_Technical_Guidance.pdf

While we have done our best to be as accurate as possible, regulations do change and we cannot take responsibility if you follow this information and the regulations have changed in the meanwhile.

If you are a client of ours, we will gladly advise you, but it will be your responsibility to confirm your label is legal.

 

So, to help further ...

The government have a free online label training course:
http://labellingtraining.food.gov.uk/

We have come across a company that is offering an affordable online course:
http://www.highspeedtraining.co.uk/food-safety/food-labelling-requirements-training.aspx
(Note: We have no connection to this company, are not affiliates etc, and cannot be held responsible for any issues that you may have with them).

 

There are various companies that offer label checking services:
Campden BRI
http://www.campdenbri.co.uk/services/food-labelling-guidance.php
Leatherhead Food Research
http://www.leatherheadfood.com/label-checks
Legal Food Label
http://www.legalfoodlabel.co.uk/services/
(Note: We have no connection to these companies, are not affiliates etc, and cannot be held responsible for any issues that you may have with them).

 

More resources:

Gov - Technical Guidance on Nutrition Labelling
https://www.gov.uk/government/publications/technical-guidance-on-nutrition-labelling
Novel Food  catalogue (what ingredients you cannot use in the UK/EU) as they classed as novel foods:
http://ec.europa.eu/food/safety/novel_food/catalogue/search/public/index.cfm
Is your product a medicine? Advice from the MHRA:
https://www.gov.uk/guidance/decide-if-your-product-is-a-medicine-or-a-medical-device
Traditional Herbal medicine - Details and how to apply for a licence:
https://www.gov.uk/guidance/apply-for-a-traditional-herbal-registration-thr