Nutritional Panel vs. Supplement Panel
We have some new potential customers that are using Supplement Facts Labels on their items instead of Nutrition Facts. The contents of the packages our within our normal scope of our manufacturing. Do we need to do anything different in our Food Safety System?
From the FDA Dietary Supplement Labeling site: https://www.fda.gov/...-labeling#4-2
The nutrition label for a dietary supplement is called a "Supplement Facts" panel (see sample labels at the end of this chapter).
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.
Thank you for responding. So my next question would be, do we need to make any changes to our Food Safety System or doing panel correctly is enough?
Stacy Surine
From the FDA Dietary Supplement Labeling site: https://www.fda.gov/...-labeling#4-2
The nutrition label for a dietary supplement is called a "Supplement Facts" panel (see sample labels at the end of this chapter).
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.
Thank you so much for responding.
Next question would be do we need to make any changes to our Food Safety System or doing panel correctly is enough?
We'd need some basic information about what you are making and what you're currently doing, but everything you do should be based on a Risk Analysis of your process.
You must follow 21 CFR 117 for food. If you are manufacturing supplements, you must follow 21 CFR 111,