Supplement rules: EU vs UK labels, claims and limits

Two systems that still look almost identical

The UK kept EU food law on leaving the EU, so the starting point is the same in both places — but the two sets of rules have begun to move apart.

• In the EU, food supplements are governed by Directive 2002/46/EC, which sets which vitamin and mineral sources may be used and what the label must say.
• In Great Britain, the equivalent rules are the Food Supplements Regulations 2003 plus retained EU law; Northern Ireland continues to follow the EU framework for food.
• Neither system licenses a supplement. There is no approval step before sale: the business placing it on the market is responsible for its safety and its labeling.
• Enforcement is local — trading standards in the UK, national food authorities in EU member states — which is why identical products can be treated differently in different countries.

Why European labels say so much less than US ones

The single biggest difference a shopper notices is wording, and it comes from claims law rather than from the ingredients.

• Regulation (EC) 1924/2006 allows only claims that appear on the authorised EU register, and Regulation (EU) 432/2012 contains the permitted general-function list.
• Every authorised claim has conditions of use — usually a minimum amount per serving — and the exact approved wording or something with the same meaning.
• Most botanical claims are still on hold and have never been authorised, which is why a herb can be sold but not described.
• Health claims referring to treating or preventing disease are prohibited outright; a product making one is being sold as an unlicensed medicine.
• The retained UK register is now maintained separately, so a claim can be permitted in one place and not the other.

Maximum levels and novel foods

Two more differences catch people out when they buy across borders: how much of a nutrient a capsule may contain, and whether the ingredient is allowed at all.

• Maximum permitted vitamin and mineral levels have never been harmonised across the EU, so national limits differ — a strength sold freely in one member state may exceed the limit in another.
• An ingredient not consumed to a significant degree in the EU before May 1997 is a novel food and needs authorisation before sale.
• The UK now runs its own novel foods register, so an authorisation in one jurisdiction does not automatically carry to the other.
• This is the usual reason a US supplement cannot lawfully be sold in Europe: not safety data, but claims wording, an unpermitted source form, or novel food status.

How to read a UK or EU supplement label

The label carries more information than it appears to, once you know the order.

• Look for the amount of the nutrient per recommended daily portion, and the percentage of the nutrient reference value where one exists.
• For minerals, check the elemental amount rather than the weight of the compound — 500 mg of magnesium citrate is not 500 mg of magnesium.
• The source form must be one of the permitted sources listed in the annexes; an unusual form is worth checking.
• A warning not to exceed the stated recommended daily dose, and a statement that supplements do not replace a varied diet, are both required — their absence suggests a product outside the system.
• If you take several products, the amounts stack. Recording what you actually take is the only way to see the total.

References

• Directive 2002/46/EC — food supplements
• Regulation (EC) 1924/2006 — nutrition and health claims made on foods
• Regulation (EU) 432/2012 — list of permitted health claims
• UK Food Supplements (England) Regulations 2003
• Food Standards Agency — regulated products and novel foods