Supplement Facts vs Nutrition Facts: which label you need
In the United States, the product category decides the panel. Dietary supplements use a Supplement Facts panel under 21 CFR 101.36. Conventional foods and beverages use a Nutrition Facts label under 21 CFR 101.9. Both panels use the same Daily Values and many of the same rounding rules from 101.9, but they are not interchangeable.
Side by side
| Topic | Supplement Facts (101.36) | Nutrition Facts (101.9) |
|---|---|---|
| Used for | Dietary supplements | Conventional foods and beverages |
| Ingredients in the panel | Dietary ingredients with a Daily Value, followed by other dietary ingredients such as botanicals and amino acids without a Daily Value, marked “†” | A fixed set of nutrients (fat, cholesterol, sodium, carbohydrate, protein, vitamin D, calcium, iron, potassium and others) in a set order |
| Source and form | May name the source of a nutrient in the panel, for example “Vitamin C (as ascorbic acid)”. Botanicals must name the plant part. | Not used in the panel |
| Proprietary blends | Allowed. The blend’s total weight is declared and its components are listed by weight (101.36(c)). | Not applicable |
| %DV for nutrients with a DRV | Nearest whole percent, with “Less than 1%” or “<1%” when the amount is present but rounds to zero (101.36(b)(2)(iii)) | Nearest whole percent (101.9(d)(7)(ii)) |
| Footnotes | “Percent Daily Values are based on a 2,000 calorie diet” when DRV nutrients are listed, plus “Daily Value not established” for † items | “*The % Daily Value tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice.” (101.9(d)(9)) |
| Type and layout | Title largest on the panel; body type at least 8 pt; boxed with hairlines (101.36(e)) | Prominent Calories line (at least 16 pt label and 22 pt number), servings information at least 10 pt (101.9(d)(1)–(3)) |
Which one applies to your product?
The category depends on how the product is intended and marketed, not on its format. A gummy, a powder or a liquid can be either a supplement or a food. If you are unsure, get regulatory advice before you design the label. A product with the wrong panel is mislabeled.
Make the right panel
- Supplements: Supplement Facts generator, plus presets for gummies, capsules and powders.
- Foods and beverages: Nutrition Facts generator (standard vertical format).
- Reference values for both: US Daily Value reference.
Sources
- Nutrition labeling of dietary supplements — U.S. Food and Drug Administration (21 CFR 101.36)
- Nutrition labeling of food (RDIs, DRVs, rounding) — U.S. Food and Drug Administration (21 CFR 101.9)