Health claims on food supplements: what EU law allows

What is a nutrition claim and what is a health claim?

A nutrition claim is about the energy or nutrient content of a food, for example ‘source of vitamin C’. A health claim links a food or one of its constituents with health, for example ‘Vitamin C contributes to the reduction of tiredness and fatigue.’ Both are governed by Regulation (EC) No 1924/2006.

A claim is any message or representation that is not mandatory and suggests a food has particular characteristics, including pictures and symbols (Art. 2(2)). For vitamins and minerals, the Annex to the Regulation sets two basic nutrition claims:

Watch your product name too. A trade mark, brand name or fancy name that could be read as a nutrition or health claim may only be used if it is accompanied by a related authorised claim (Art. 1(3)).

Where do you find the authorised health claims?

Authorised claims are listed in Commission Regulation (EU) No 432/2012, which applies from 14 December 2012, and in the EU Register of nutrition and health claims on the European Commission’s website. The Register shows authorised and non-authorised claims and can be exported to Excel.

• Only from the list. Health claims are prohibited unless they are authorised and included in the EU lists (Art. 10(1) of Regulation 1924/2006).
• Same meaning, same conditions. Wording that has the same meaning for consumers as an authorised claim is subject to the same conditions of use (recital 9 of Regulation 432/2012).
• Your language. Regulation 432/2012 exists in every official EU language. On a label for a given country, use the official language version for that market.
• The list changes. Regulation (EU) 2024/2041, for example, removed the claim for monacolin K from red yeast rice. Check the current wording before every print run.

Which claims are authorised for vitamin C, D, K, B6, B12, magnesium, zinc and selenium?

For these eight nutrients, Regulation 432/2012 contains 76 authorised claims. The table shows how many there are and the ‘source’ threshold calculated from the nutrient reference values (NRV) in Annex XIII of Regulation (EU) No 1169/2011:

A selection of authorised claims, word for word from the English consolidated text of Regulation 432/2012 (20 August 2025):

All of the claims above have the same condition of use, for example for vitamin C: ‘The claim may be used only for food which is at least a source of vitamin C as referred to in the claim SOURCE OF [NAME OF VITAMIN/S] AND/OR [NAME OF MINERAL/S] as listed in the Annex to Regulation (EC) No 1924/2006.’

Some claims have their own condition. ‘Vitamin C contributes to maintain the normal function of the immune system during and after intense physical exercise’ may only be used for food that provides a daily intake of 200 mg of vitamin C, and consumers must be told that the effect is obtained with 200 mg in addition to the recommended daily intake.

When may you use a claim?

You may use a claim if the supplement contains enough of the substance and the label carries the required accompanying information.

Significant amount. ‘Source’ means a significant amount as defined in Annex XIII, Part A, point 2 of Regulation 1169/2011. As a rule, that is 15% of the NRV per 100 g or 100 ml, or per portion if the package contains only a single portion. For food supplements:

• The Czech food inspection authority (SZPI), in its guidance of 3 January 2024, states that for food supplements it is 15% of the NRV in the recommended daily dose.
• There is no binding EU-wide interpretation. In our reading, calculating 15% of the NRV in the recommended daily dose is the reasonable approach.
• The substance must also be in a form that is available to be used by the body (Art. 5(1)(c) of Regulation 1924/2006).

Accompanying information (Art. 10(2)). If a supplement carries a health claim, the labelling (or, if there is no labelling, the presentation and advertising) must include:

1. a statement on the importance of a varied and balanced diet and a healthy lifestyle,
2. the quantity of the food and pattern of consumption needed to obtain the claimed effect,
3. where appropriate, a statement for people who should avoid the product,
4. an appropriate warning for products likely to present a health risk if consumed to excess.

General claims. A reference to general, non-specific benefits, such as ‘for immunity’ or ‘for vitality’, may only be made together with a specific authorised claim (Art. 10(3)).

What may you never claim?

Whatever the formula, you may never claim that a supplement prevents, treats or cures a disease (Art. 7(3) and (4) of Regulation 1169/2011, Art. 6(2) of Directive 2002/46/EC). This applies to the label, the presentation and advertising. You also may not state or imply that a balanced and varied diet cannot provide enough nutrients (Art. 7 of Directive 2002/46/EC). Under Art. 12 of Regulation 1924/2006, claims are not allowed that:

• suggest that health could be affected by not consuming the food,
• refer to the rate or amount of weight loss,
• refer to recommendations of individual doctors or health professionals.

Reduction of disease risk claims are a separate category. They may only be used if specifically authorised under Art. 14 of Regulation 1924/2006; Regulation 432/2012 does not contain them. In consumer law, falsely claiming that a product can cure illnesses is always an unfair commercial practice (Directive 2005/29/EC, Annex I, point 17).

National advertising laws can add rules. In Slovakia, advertising must not present food supplements as if they had the effects of medicines (Act No 147/2001 Coll., § 3(1)(f)); in Czechia, an advertisement for a supplement must clearly include the words ‘doplněk stravy’ (Act No 40/1995 Coll., § 5d(3)).

Why is ‘better absorption’ not an authorised claim?

A claim of better absorption or higher bioavailability is not an authorised health claim. In its 2010 opinion (EFSA Journal 2010;8(10):1743), the EFSA panel found that such claims refer to the improved bioavailability of a nutrient, not to a relationship between a food and health as Regulation 1924/2006 requires.

You may describe the form factually, for example ‘magnesium in liposomal form’. You may not link it to greater effect or use multiples such as ‘2× better’. The authorised claims ‘Vitamin C increases iron absorption’ and ‘Vitamin D contributes to normal absorption/utilisation of calcium and phosphorus’ describe the role of the nutrient in the body, not a property of your product form. More in Liposomal supplements explained.

What applies to botanical claims ‘on hold’?

Claims about plant substances (botanicals) that EFSA has not yet evaluated, or that the Commission has not yet considered, may continue to be used under Art. 28(5) and (6) of Regulation 1924/2006 (recitals 10 and 11 of Regulation 432/2012). According to the European Court of Auditors (special report 23/2024), 2,078 botanical claims remain on hold.

The Court of Justice of the EU narrowed their use in judgment C-386/23 of 30 April 2025. Until the Commission completes its examination, the advertising of a supplement made from botanical substances may not use:

• specific claims describing or referring to psychological or behavioural functions (such as mood or stress),
• references to general, non-specific benefits for overall health without an authorised specific claim,

unless Art. 28(6) of Regulation 1924/2006 permits them.

The judgment did not expressly exclude on-hold claims about physical functions. In our reading, using them is at your own responsibility and risk. National guidance may predate the judgment: the Czech SZPI guidance of 3 January 2024, for example, was issued before it. The safer route is to combine the plant with a vitamin or mineral that has an authorised claim.

Do the rules apply to websites, social media and influencers?

Yes. Regulation 1924/2006 applies to claims in commercial communications, whether in the labelling, presentation or advertising of foods (Art. 1(2)). Your website, online shop, newsletter and social media posts are commercial communications.

• Professional audiences. In judgment C-19/15 (14 July 2016), the Court of Justice ruled that the Regulation also applies to commercial communications aimed exclusively at health professionals. In our reading, the same rules therefore apply to catalogues for pharmacies and materials for distributors.
• Influencers. In our reading, a paid influencer post is advertising for your brand, so the same claim rules apply. Its commercial intent must also be clear: under the Unfair Commercial Practices Directive (2005/29/EC), hiding the commercial intent is a misleading omission (Art. 7(2)), and paid editorial content not identified as such is always unfair (Annex I, point 11).
• Customer reviews. EU law does not address them expressly. In our reading, if you select, highlight or share reviews as marketing, they can become your own commercial communication.

Who enforces the rules, and what are the risks?

Each member state enforces the rules through its own authorities and sets its own penalties. Official controls follow Regulation (EU) 2017/625; authorities may, for example, order products online without identifying themselves and use them as official samples (Art. 36).

Examples of penalties for misleading or non-compliant claims (as at 17 October 2026):

Besides fines, authorities can order you to change labels and advertising or to withdraw products from the market. Penalties and enforcement practice differ between countries, so check the rules of each country where you sell.

How can we help?

We prepare label texts in line with the rules, in selected languages: ingredients, amounts per daily dose with % NRV, directions, mandatory warnings and storage. The choice of health claims is yours; we do not offer it as a service. As the brand owner, you are responsible for the claims you use.

The other mandatory particulars are in Food supplement label requirements, and notification is explained in Food supplement notification in the EU. Label printing and application is described on the Labels page. For questions, send us an enquiry.