A Supplement Facts panel is the FDA-mandated nutrition label required on every dietary supplement and it follows different formatting rules than the Nutrition Facts panel used on food. Shehadeh Giannamore, PLLC reviews Supplement Facts panels for accuracy, formatting, and FDA compliance before you print packaging, catching the serving-size, disclosure, and formatting errors that trigger warning letters and Amazon/retailer delisting alike.
| Who needs this | Any company manufacturing or marketing a dietary supplement in the U.S. |
| What’s reviewed | Supplement Facts panel formatting, serving size, %DV calculations, proprietary blend disclosure, required disclaimers |
| Legal basis | 21 CFR § 101.36; DSHEA (1994); FD&C Act misbranding provisions (21 U.S.C. § 343) |
| What’s at stake | Misbranding violations, warning letters, retailer and marketplace delisting |
| Related page | See Ingredient Reviews to confirm the ingredients themselves are legal before finalizing the panel |
What Is a Supplement Facts Panel?
The FDA requires every dietary supplement to display a Supplement Facts panel a specific, standardized format for disclosing serving size, the supplement’s ingredients, and the amount per serving of each. It sits alongside other Principal Display Panel requirements like the Statement of Identity and Net Quantity of Contents, but the Supplement Facts panel itself has its own formatting rules set out in federal regulation, and small formatting deviations are among the most commonly cited violations in FDA warning letters to supplement companies.
Supplement Facts Panel vs. Nutrition Facts Panel
This is the single most common point of confusion for new supplement brands: dietary supplements are technically a subset of “food” under the FD&C Act, but they do not use the Nutrition Facts panel that conventional foods use. They require the distinct Supplement Facts panel format, which allows for different content — including proprietary blends and “other ingredients” — that the Nutrition Facts format does not accommodate. Using the wrong panel format is, on its own, a misbranding violation regardless of how accurate the underlying information is.
What Our Supplement Facts Panel Review Covers
- Serving size and servings per container confirmed against actual product use and FDA reference amounts
- %Daily Value calculations for every nutrient with an established Daily Value
- Ingredient listing order descending order by weight, correctly separating dietary ingredients from “other ingredients”
- Proprietary blend disclosure total blend weight disclosed even when individual amounts are proprietary
- Required disclaimer placement and wording the structure/function claim disclaimer, where applicable
- Footnote and formatting compliance type size, panel borders, and required “Supplement Facts” heading formatting under 21 CFR § 101.36
Common Supplement Facts Panel Mistakes
- Using a Nutrition Facts panel format instead of the required Supplement Facts format
- Listing a proprietary blend without disclosing its total weight
- Omitting or miswording the mandatory “not evaluated by the FDA” disclaimer next to a structure/function claim
- Incorrect serving size that doesn’t match actual recommended use
- Missing “other ingredients” declarations for excipients, fillers, or capsule material
Not sure if your current label or marketing would survive an FDA review? Get an attorney's eyes on it before you find out the hard way.
Schedule a ConsultationOur Supplement Facts Panel Review Process
- Submit your draft panel and formula including serving size, ingredient breakdown, and any proprietary blend details
- Format and content review against 21 CFR § 101.36 requirements
- Written findings flagging formatting errors, missing disclosures, and disclaimer issues
- Revised panel language provided in FDA-compliant format
- Final proof review before the panel goes to print
- What is a Supplement Facts panel?
- A Supplement Facts panel is the FDA-mandated nutrition disclosure label required on dietary supplements, showing serving size, ingredients, and the amount per serving, in a specific format set out in 21 CFR § 101.36.
- How is a Supplement Facts panel different from a Nutrition Facts panel?
- Dietary supplements must use the Supplement Facts format rather than the Nutrition Facts format used on conventional food, even though supplements are technically classified as a subset of food the two formats have different required fields and formatting rules.
- Do I need to disclose a proprietary blend’s exact ingredient amounts?
- No, but you must disclose the total weight of the proprietary blend as a whole, and every ingredient in it, listed in descending order by weight.
- What disclaimer is required on a Supplement Facts panel?
- If the label makes a structure/function claim, the panel or nearby label area must include the disclaimer that “This statement has not been evaluated by the FDA. This product is not intended to diagnose, treat, cure, or prevent any disease.”
- What happens if my Supplement Facts panel format is wrong?
- An incorrectly formatted panel is a misbranding violation under the FD&C Act regardless of whether the underlying nutrient information is accurate, and can trigger a warning letter or retailer delisting independent of any other label issue.
Talk to a Supplement Facts Panel Attorney
Before you finalize packaging, get your Supplement Facts panel reviewed against current FDA formatting rules. Contact Shehadeh Giannamore, PLLC for a consultation.
Toll-free: (866) 785-0873
Direct: (305) 507-9843
Email: contact@giannamore-law.com
Schedule a ConsultationThis page is for general informational purposes only and does not constitute legal advice or create an attorney-client relationship.