Formulation

Food supplements: the daily dose is what counts, not the 100 g

Amber bottles and capsules on a lab bench, analytical balance in the background

A food supplement is not declared like a food. Nobody eats 100 g of capsules: what counts is the recommended daily portion, and the share of the nutrient reference value it delivers. A per-100 g nutrition table answers neither question — and yet it is where you have to start to reach the label.

What a supplement declares, and a food does not

Directive 2002/46/EC governs the labeling of food supplements. It requires a recommended daily portion, the amount of each nutrient or substance that portion delivers, and its percentage of the nutrient reference value where one exists — plus a warning not to exceed the stated dose.

Three substantive differences from a food label follow:

  • the unit of declaration is the dose, not 100 g;
  • actives are counted in milligrams or micrograms, sometimes far above 100 % of the reference;
  • the raw material is almost never the active itself: you weigh out zinc gluconate to deliver zinc, and its assay makes all the difference.

The per-dose value is not a simple division

Take a 600 mg capsule delivering 500 mg of vitamin C and 10 mg of zinc. None of that is what gets entered on the formula: what you enter is 30 g of ascorbic acid and 4.2 g of zinc gluconate assayed at 14.3 %, for a batch of 60 capsules. The rest is derived.

Nutrition table of a food supplement in beCPG: vitamin C and zinc with the value per 100 g, the value per capsule, the labelled value with its tolerances and the percentage of the reference intake

The “1 portion” column gives the expected 500 mg and 10 mg, and the percentage follows: 625 % of the reference for vitamin C, 100 % for zinc. The labeled value arrives framed by its control tolerances — because that is the figure, not the calculated one, that will be set against a laboratory result.

One formula, several markets

This is where a spreadsheet becomes genuinely uncomfortable. The dose does not move from one country to the next: 500 mg of vitamin C stays 500 mg. But the reference value it is measured against does change — and so does the percentage printed on the carton.

One 500 mg vitamin C capsule: the dose does not change, the reference value does
MarketVitamin C reference valuePercentage for 500 mg
European Union80 mg625 %
United States90 mg556 %
China100 mg500 %
Brazil100 mg500 %
Russia (Eurasian Economic Union)60 mg833 %
Australia40 mg1,250 %
Reference values: Regulation (EU) No 1169/2011 (Annex XIII), 21 CFR 101.9 (FDA), GB 28050-2011 (China), ANVISA IN 75/2020 (Brazil), TR CU 022/2011 (Eurasian Economic Union), Food Standards Code, Schedule 1 (Australia). Percentages before rounding: each regulation then applies its own rules.

A ratio of two and a half between Australia and China, on the very same product. Rounding and tolerances differ by regulation as well. In beCPG, the labeled value follows the rounding rules and tolerances of the sales countries, from the same formula: there is no per-country table to copy, there is one formula and a set of regulations applied to it.

What formulation should stop before the plant does

Supplements rarely go half wrong. An assay carried over incorrectly, a milligram mistaken for a microgram, an active dosed beyond what the target market allows: the error shows up neither at blending nor at packing. It shows up on a laboratory report, or in a letter from an authority.

Hence the value of setting bounds on the formula itself. A minimum and a maximum per nutrient, checked at every reformulation, turn a label proofread into a control that fires on its own. The principle is the same as for checking products against the British HFSS thresholds: whatever a rule can verify should not be verified by hand.

Where to start

The starting point is not the label, it is the raw material repository: the assay of each active, its unit, its permitted form. Once that base is right, the dose, the percentages and the per-market variants are nothing more than arithmetic.

If you would like to test this against your own range and your export markets, get in touch.

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