Thirst quenching, energy-boosting, or just plain tasty—the beverage market is diverse and requires a wide set of regulations. Some products are regulated as supplements while others are deemed standard food items, but what’s the difference on the manufacturing end?
The supplement facts label and the nutrition facts label are both designed to communicate what’s in a beverage, but the information and function of these two label types can be vastly different.
We’re here to guide you through the differences and similarities between these federally mandated fact lists. It’s time to explore ingredient sourcing, claims, disclaimers, and a whole lot more.
Nutrition vs Supplement Facts: Serving Size
At the top of both nutrition and supplements facts labels, manufacturers are required to list out serving sizes in accordance with FDA regulations. The specific wording of “Serving Size” is required terminology for all food and beverage products and should not be altered on any fact label.
Take note that both supplement and nutrition facts will look almost identical in the serving size section.
The serving size standards for various ingredients as recommended by the FDA include:
- Fluid ounces – For all beverages, manufacturers may use measurements in fluid ounces. You may also include liters or milliliters, clearly listed alongside in parentheticals. The standard serving size of carbonated and noncarbonated beverages, as well as wine coolers and water, is 12 fluid ounces (360 milliliters). Hot beverages like coffee and flavored tea are also included in this recommendation.
- Dual column – For larger, multi-serving beverages, it may be necessary to include a second column of nutrition fact information regarding the entire container. The second column can help consumers delineate between what a recommended serving is and what the total product contains.
The nutrition and supplement facts panel regarding serving sizes should be extremely familiar to manufacturers and consumers alike. It’s designed to make it easy to understand what the listed calories, fat, total sugar, and other nutrients are in reference to.
Nutrition vs Supplement Facts: Ingredients Sourcing
Nutrition fact panels are typically straightforward when listing ingredients. On the other hand, supplement facts labels can have special responsibilities for disclosure, as well as some unique opportunities to share more details with their customers.
What does that mean in the context of fact labels? Consider the following:
- Protein sources – Added protein is a staple of many supplement beverages, and where that protein comes from can be important to consumers. Supplement fact labels may include various sources (animal, plant, dairy) for their protein. In contrast, this listing should not be included on a nutrition facts panel.
- Specific plant parts – Various plants and herbs are common to supplements, and the FDA requires supplement manufacturers to specify not only the plant but the part of the plant from which an ingredient is sourced.
Nutrition vs Supplement Facts: Daily Values and Amounts
The percentage of daily value is required for ingredients listed on both nutrition and supplement facts. When crafting either facts label, it’s necessary to include a complete list of ingredients and the daily value as established by the FDA.
When dealing with a nutrition and supplement fact label, manufacturers must list the following ingredients as well as their daily values:
- Total fat
- Saturated fat
- Trans fat
- Cholesterol
- Sodium
- Total carbohydrate
- Dietary fiber
- Total sugars
- Added sugars
- Protein
- Specific vitamins and minerals (Vitamin D, Vitamin A, calcium, iron, and potassium)
Additionally, supplement manufacturers should take note of these special terms:
- Claims related to ingredients – If your product makes any health claim relating to specific ingredients, those ingredients must be included on the supplement facts panel. This could take the form of saturated fat, sugar alcohol, fibers, or carbohydrates. If you’re stating anything regarding these nutrients, be certain to include them.
- Proteins vs amino acids – You are not permitted to list add amino acids under protein on the supplement facts label. While amino acids may function similarly to amino acids, your label cannot equate these two compounds.
- No zero-amounts – While nutrition labels may list zero total amounts (0 calories, 0 fat, etc.), supplement labels are not permitted to display zero amounts. If your supplement doesn’t contain a macro-nutrient, it should simply be left off the facts panel.
It should be made clear that any and all ingredients that do not fall under the above categories should still be listed. All food and beverage products are required to be fully transparent about their contents and ingredients must be listed by their common names.
Nutrition vs Supplement Facts: Claims
Food products frequently make claims regarding various health benefits. For manufacturers, this can be a great way to provide further incentive to your customers. For customers, these claims encouraged discerning purchases, based on dietary needs and wants. Food labeling plays an integral part in communicating product values to the consumer with minimal wording and confusion.
A product with nutrition fact panels that are regulated as standard foods or beverages frequently make claims like:
- High in fiber
- A good source of protein
- Gluten-free
- Low fat
- Light or lite
Specific health claims that are verified by the FDA and verified by scientific data may fall under the categories of:
- NLEA authorized health claims – These claims are authorized by the FDA under the Nutrition Labeling and Education Act of 1990 and refer specifically to a food, a food component, or dietary ingredient and risk of disease. Products that claim to reduce the risk of certain diseases like stroke, heart disease, or osteoporosis may fall under this category.
- Health claims based on authoritative statements – Backed by the US government or National Academy of Sciences, these claims also require specific consent from the FDA to use for food products and do not extend to supplements. These claims may include a specific scientific recommendation from these authoritative bodies.
Additionally, products with supplement facts panels may engage in claims like:
- Nutrient Content Claims – Related to specific nutrient net quantity. A product may claim to be “light” or “low” based on the contents of a product and the recommended daily intake values.
- Structure/Function Claims – These claims do not require preapproval by the FDA. Typically these claims state how a specific nutrient relates to health (“Calcium to maintain bone health,” “antioxidants support cell integrity”) and require manufacturers to maintain that all claims are truthful. In other words, manufacturers must have a means of backing up their specific claims.
For products regulated as supplements, it’s important to never include direct statements about a supplement’s impact on health. The only products that can be said to treat or cure specific illnesses or diseases are FDA-regulated drugs.
Nutrition vs Supplement Facts: Disclaimers and Warnings
FDA rules around food and beverage products imply a specific level of scrutiny and manufacturing standards. Products with an attached nutrition label are highly regulated and are required to adhere to specific standards that supplement products are not.
While supplements must still follow FDA guidelines, there are differences in standards that require supplement fact labels to display the following:
- FDA Disclaimer – Standard food products include FDA disclaimers or warnings, but any supplements making specific claims will come with a message at the bottom of the supplement facts panel. For maximum transparency, place a clear statement such as, “This statement has not been evaluated by the FDA. This product is not intended to diagnose, treat, cure, or prevent any disease.”
- Ingredient advisory list – Certain ingredients are currently under investigation by the FDA regarding their food safety. These ingredients have not been determined as unsafe, but their use in dietary supplements is in question. The FDA advises against using Sulbutiamine, Andarine, Bismuth nitrate, and several others. View the advisory list to get a better understanding of current federal regulations.
Nutrition vs Supplement Facts: Exceptions
While most food and beverage products require specific FDA labeling, some products may not need a nutrition or supplement fact label whatsoever. It’s rare to find exemptions to FDA regulations, but some designations have been created to protect businesses from unnecessary labeling.
Your products may be exempt from FDA nutrition and supplement facts labeling in the following scenarios:
- Small businesses – If your operation is relatively small—with less than $50,000 in gross sales, fewer than 100,000 units sold, or fewer than 100 full-time employees, your product may be exempt from nutrition label requirements. As a manufacturer, it’s essential that you stay in contact with the FDA if you’re interested in a potential exemption from specific regulations.
- No-consumer products – For bulk manufacturers that ship their products for use in further manufacturing, it’s likely that labeling is unnecessary. Products used in this way do not make specific claims as they’re not intended for consumer use.
- Alcoholic beverages – The majority of alcoholic beverages are not regulated by the FDA but by the Alcohol and Tobacco Tax and Trade Bureau. Alcoholic beverage manufacturers are subject to an entirely different set of rules and regulations and do not need nutrition or supplement labeling.
Keep The Facts Straight with Wildpack Beverage
Even with the information provided in this article, it may still be difficult to determine precisely what to include on your beverage. Not only are you at the discretion of federal regulating bodies, but you’re also in a race to stay competitive and to appeal to customers.
If you’re ready to get your labeling on track and set up for success, it’s time to partner up with Wildpack Beverage.
As industry leaders, we have the tools to help you craft an attractive, inviting, and fully compliant can label. Whether you’re producing supplement beverages, standard sodas, or mouthwatering brews, we have you covered with sleeving, packaging, and so much more. Visit us today to bring your vision to life.
Sources:
FDA. Dietary Supplement Labeling Guide: Chapter IV. Nutrition Labeling. https://www.fda.gov/food/dietary-supplements-guidance-documents-regulatory-information/dietary-supplement-labeling-guide-chapter-iv-nutrition-labeling
FDA. Food Labeling: Serving Sizes of Foods That Can Reasonably Be Consumed At One Eating Occasion; Dual-Column Labeling; Updating, Modifying, and Establishing Certain Reference Amounts Customarily Consumed; Serving Size for Breath Mints; and Technical Amendments: Guidance for Industry Small Entity Compliance Guide. https://www.fda.gov/media/111144/download
FDA. Which Nutrients Are Required to Be Listed on the Nutrition and Supplement Facts Labels?. https://www.fda.gov/food/new-nutrition-facts-label/daily-value-new-nutrition-and-supplement-facts-labels
FDA. New Dietary Ingredients in Dietary Supplements – Background for Industry.
FDA. Label Claims for Conventional Foods and Dietary Supplements. https://www.fda.gov/food/food-labeling-nutrition/label-claims-conventional-foods-and-dietary-supplements
FDA. Questions and Answers on Dietary Supplements. https://www.fda.gov/food/information-consumers-using-dietary-supplements/questions-and-answers-dietary-supplements
FDA. Dietary Supplement Ingredient Advisory List. https://www.fda.gov/food/dietary-supplement-products-ingredients/dietary-supplement-ingredient-advisory-list
