What is a Supplement Facts panel?
The Supplement Facts panel exists because of the Dietary Supplement Health and Education Act of 1994 (DSHEA), which created dietary supplements as their own regulatory category. Foods carry a Nutrition Facts panel; dietary supplements carry Supplement Facts.
The panel lists dietary ingredients. Vitamins and minerals sit next to substances with no established Daily Value, such as botanicals and amino acids. For each one, it shows the amount per serving and, where a Daily Value exists, the percent Daily Value (%DV). The FDA's Dietary Supplement Labeling Guide walks through each element with examples (FDA, Dietary Supplement Labeling Guide).
Which products need Supplement Facts
Any product marketed as a dietary supplement needs a Supplement Facts panel, whatever its dosage form, from capsules to liquids. Conventional foods and beverages use Nutrition Facts.
The line is drawn by intended use, not by physical form. Protein powders and meal replacements can fall on either side. Two nearly identical formulas may need different panels depending on how the product is labeled and marketed. A product carries one panel or the other, never both, so the classification decision comes before any label work.
What's required on a Supplement Facts panel
Serving size and servings per container
The panel opens with the serving size, stated in the unit the consumer takes: "1 capsule" or "2 gummies." Servings per container follows. The serving size has to match the directions for use on the label.
Dietary ingredients with a Daily Value
Nutrients with an established Daily Value are declared by amount per serving and %DV. Nutrients such as total fat or total carbohydrate are declared only when present above the amount that could be declared as zero. Unlike Nutrition Facts, a Supplement Facts panel does not list nutrients at zero.
When a product is intended for infants, children under 4, or pregnant and lactating women, the %DV is calculated against the Daily Values for that population (21 CFR 101.36).
Other dietary ingredients
Ingredients with no established Daily Value, such as botanicals and amino acids, are still declared by name and amount per serving. In place of a %DV, they carry a symbol pointing to a footnote stating that a Daily Value is not established. A heavy line separates them from the ingredients that have a Daily Value.
Proprietary blends
A proprietary blend lists its total weight per serving, with ingredients in descending order of predominance by weight. Individual amounts can stay undisclosed only for ingredients that have no Daily Value. Any vitamin or mineral with a Daily Value still has to be listed with its amount and %DV, even when it's part of a blend.
Source and plant part
The panel can show the source of a nutrient, such as "Magnesium (as magnesium glycinate)." When the source appears in the panel, it does not need to repeat in the ingredient statement. Botanical ingredients must name the part of the plant used, such as "Turmeric (root)."
Supplement Facts formatting rules
21 CFR 101.36 regulates how the panel looks as well as what it says:
- The title "Supplement Facts" is set larger than all other type in the panel and runs its full width, unless that is impractical.
- The title and headings are bold.
- The panel sits inside a box drawn with hairlines.
- All information uses a single, easy-to-read type style.
- Nutrient names align left, with amounts and %DV in columns to the right; subcomponents are indented.
The FDA publishes sample Supplement Facts labels for the standard formats. Type size minimums depend on the package, so the art team should confirm them against the regulation for each package size (FDA, sample Supplement Facts label).
What goes outside the Supplement Facts box
Several required elements sit on the label but outside the panel:
- Other ingredients. Inactive components such as capsule materials, flavors, and colors go in an ingredient list below the panel, in descending order by weight.
- Allergens. The nine major food allergens must be declared when present.
- Statement of identity. The product name identifies it as a dietary supplement.
- Net quantity. For example, "60 softgels."
- Manufacturer, packer, or distributor. Name and place of business.
- Structure/function disclaimer. A claim such as "supports immune health" requires the FDA disclaimer: "These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease." The manufacturer, packer, or distributor must also notify the FDA no later than 30 days after first marketing the product with that claim (21 CFR 101.93).
Supplement Facts vs. Nutrition Facts
The FDA's labeling guide lists the core differences between the two panels. Nutrition Facts follows 21 CFR 101.9; Supplement Facts follows 21 CFR 101.36.
| Element | Supplement Facts | Nutrition Facts |
|---|---|---|
| Product type | Dietary supplements | Conventional foods and beverages |
| Ingredients without a Daily Value | Must be listed | Not permitted |
| Source of a nutrient ("as magnesium glycinate") | Permitted in the panel | Not permitted in the panel |
| Plant part of a botanical | Required | Not permitted |
| Nutrients present at zero | Not listed | Required |
| Proprietary blends | Declared with total weight | Not used |
How to build a Supplement Facts panel from your formula
The panel is the output of a formula record. When the record is right, the panel follows; when the record is split across spreadsheets and a separate label tool, the panel inherits every gap between them.
- Declare the label claim, not the batch amount. Formulators add overages so a vitamin still meets its declared amount at the end of shelf life, since potency drops over time. The product has to deliver at least what the label states, so the panel declares the label claim and the overage stays in the formula. Supplement formulators raise this question in SKUsafe's sales calls, because an overage entered as a plain quantity ends up printed on the panel.
- Convert salts to the nutrient amount. The formula buys calcium carbonate; the panel declares calcium. The amount on the panel is the elemental nutrient, with the salt shown as the source. The conversion factor should live on the ingredient record, so every formula using that ingredient applies it the same way.
- Build the blend from its components. A proprietary blend's total weight and order of predominance come straight from the formula. Hand-typing them into a label tool is how the declared order drifts from the actual one.
- Match the panel to your brand's format. Every brand has its own conventions for symbols, placement, and blend display. One formulation scientist described their company's panels as "weirdly specific," and those rules belong in the label settings rather than in each designer's memory.
- Tie the panel to a formula version. A reformulation changes the panel. When the panel is generated from a specific formula version and approved against it, the printed label can always be traced back.
- Keep a checkpoint on co-manufacturer data. Brands that rely on their co-manufacturer to calculate the panel still need to verify it against their own formula record before approval.
SKUsafe generates the Supplement Facts panel directly from the formula. Overages and potency are recorded per ingredient, so the panel declares the label claim.
Proprietary blends and Daily Values by population are handled in the same workspace, and a live preview updates while R&D formulates.
Every panel moves through approval with electronic signatures and locks once released. More than 80 food brands, co-manufacturers, and ingredient suppliers use the platform, including supplement brands and the co-manufacturers that produce for them.
Common Supplement Facts mistakes
- Using the wrong panel. A product positioned as a food carries Supplement Facts, or the reverse.
- Declaring the overage. The panel shows the batch amount instead of the label claim.
- Declaring the salt instead of the nutrient. The panel lists the weight of calcium carbonate rather than the calcium it provides.
- A symbol with no footnote. An ingredient without a Daily Value carries the symbol, but the footnote is missing.
- A blend without its total weight. Or components listed out of order of predominance.
- A blend that hides a vitamin or mineral. A nutrient with a Daily Value sits inside the blend without its own amount and %DV.
- Using outdated units. Folate is now declared in mcg DFE (with folic acid shown in parentheses when it's added), vitamin A in mcg RAE, vitamin E in mg, and vitamin D in mcg rather than IU.
- A serving size that contradicts the directions. The panel says one capsule; the directions say two.
- A label behind the formula. The formula changed after approval and the panel was never regenerated.
Supplement Facts compliance checklist
- Product classified as a dietary supplement based on intended use
- Serving size matches the directions for use
- Nutrients with a Daily Value declared with amount and %DV
- Nutrients present at zero left off the panel
- Other dietary ingredients declared with amount and a footnoted symbol
- Proprietary blends declared with total weight and components in order
- Vitamins and minerals inside a blend declared with their own amount and %DV
- Plant part named for every botanical
- Nutrient amounts declared as the elemental amount, with the source
- Nutrient units current (mcg DFE, mcg RAE, mg for vitamin E, mcg for vitamin D)
- Declared amounts match the label claim, with overages excluded
- Title, box, and type style follow 21 CFR 101.36
- Other ingredients, allergens, and disclaimer present outside the panel
- FDA notified within 30 days of first marketing any structure/function claim
- Panel approved against the current formula version
Frequently asked questions
Can a product have both a Supplement Facts and a Nutrition Facts panel?
No. A product carries one panel, based on its classification. Dietary supplements use Supplement Facts and conventional foods use Nutrition Facts.
Does every ingredient on a Supplement Facts panel need a %DV?
Only ingredients with an established Daily Value. Ingredients without one, such as most botanicals and amino acids, show the amount per serving and a symbol referring to a footnote.
What is a proprietary blend on a supplement label?
A combination of dietary ingredients declared under a single name with the total weight of the blend per serving. The components appear in descending order of predominance. Individual amounts can stay undisclosed only for ingredients with no Daily Value; vitamins and minerals in the blend still show their amount and %DV.
Are overages declared on the Supplement Facts panel?
No. The panel declares the label claim, which the product must meet through its shelf life. The overage added to cover potency loss stays in the formula.
Is the structure/function disclaimer required?
Yes, whenever the label makes a structure/function claim such as "supports bone health." The disclaimer must appear with the claim, in the exact wording the FDA requires. The manufacturer, packer, or distributor must also notify the FDA no later than 30 days after first marketing the product with that claim.
What regulation governs the Supplement Facts panel?
21 CFR 101.36, under the authority of DSHEA. The FDA's Dietary Supplement Labeling Guide explains the requirements with examples.
Build your Supplement Facts panel from the formula
Label errors are cheapest to fix before they reach the printer, and most of them are formula errors. To compare formulation platforms that handle supplement labeling, see our formulation software guide.
SKUsafe demos run on your own products: send a supplement formula and a few supplier spec packets, and the team builds the Supplement Facts panel in the platform live. Book a demo.