Supplements

Dietary supplements are federally regulated: cGMP, label format and claim rules.

Federal Rules Apply
Part 111cGMP
30 daysClaim notice to FDA
FactsSupplement Facts panel
SeriousAdverse events reported

What is covered and what needs a different path

What this guide covers

  • Vitamins, minerals and botanical supplements made under cGMP
  • Products with accurate Supplement Facts panels
  • Structure-function claims with the required disclaimer
  • Products from a registered food facility

Needs a different path

  • Disease treatment claims
  • Products with undeclared ingredients
  • Manufacturing in a home kitchen
  • Unnotified structure-function claims

Three compliance steps

A

Build to cGMP

Follow 21 CFR Part 111 for manufacturing, testing and records.

B

Label right

Supplement Facts panel, ingredient list, name and address, domestic phone or address for adverse events.

C

Notify FDA

Structure-function claims require a notice within 30 days of marketing, and the disclaimer on the label.

Quick reference

ItemRuleRegulator
cGMPRequired for manufacturersFDA 21 CFR 111
LabelSupplement Facts and statement of identityFDA 21 CFR 101.36
ClaimsNotice within 30 days; disclaimerFDA
Adverse eventsSerious events reportedFDA
FacilityFood registration and DPH permitFDA; DPH 105 CMR 500

Frequently asked questions

Can I make them at home?No, supplements are not cottage foods.
Can I say it cures?No, that is a drug claim.
Do small makers need cGMP?Yes, cGMP applies to all makers.

Printable checklist

  • cGMP system built
  • Supplement Facts panel
  • Disclaimer on label
  • Structure-function notice filed
  • Adverse event process
  • Facility permit
  • No disease claims