Key points
- In UK law, a food supplement is a concentrated source of a nutrient or other substance, sold in measured units such as capsules, tablets or drops, whose purpose is to supplement the normal diet.
- Food supplements are regulated as food, not as medicines.
- A supplement must be sold under the name "food supplement", which is why the words appear on the pack.
- The words name a legal category. They are not an approval, and they say nothing about what a product will do for you.
What is a food supplement? In the UK it is a legal category: a food whose purpose is to supplement the normal diet, sold as a concentrated source of a vitamin, mineral or other substance in measured units such as capsules, tablets or drops. This guide explains the definition, the line with medicines, what a label has to show and what the term does not tell you.
The legal definition, in plain English
In England, the definition is in regulation 2 of the Food Supplements (England) Regulations 2003. A food supplement means "any food the purpose of which is to supplement the normal diet and which (a) is a concentrated source of a vitamin or mineral or other substance with a nutritional or physiological effect, alone or in combination; and (b) is sold in dose form".
Taken piece by piece, that means four things:
- It is a food. The law treats a supplement as a type of food, even when it looks like a tablet or a capsule.
- Its purpose is to add to a normal diet, not to stand in for a varied one.
- It is concentrated. It is a concentrated source of a vitamin, a mineral or another substance with a nutritional or physiological effect, on its own or in combination.
- It comes in measured units. The same regulations define "dose form" as forms such as capsules, pastilles, tablets, pills, sachets of powder, ampoules of liquids, drop dispensing bottles, and similar forms "designed to be taken in measured small unit quantities".
Scotland, Wales and Northern Ireland each have their own food supplements regulations, listed in the Food Standards Agency's guidance.
Food supplement or medicine: where the line sits
The Food Standards Agency's guidance is direct about this. Food supplements "are not medicinal products and as such cannot exert a pharmacological, immunological or metabolic action". It adds that their use is not intended to treat or prevent diseases in humans or to modify physiological functions.
Whether a particular product is a medicine is decided by the Medicines and Healthcare products Regulatory Agency (MHRA), case by case. Its Guidance Note 8, A guide to what is a medicinal product, explains how.
"Medicinal by function" and "by presentation"
The Human Medicines Regulations 2012 define a medicinal product in two parts, which the MHRA calls two limbs. A product is a medicine if either one applies.
- By presentation: the product is presented as having properties for treating or preventing disease in human beings. The MHRA looks at every claim made for it, explicit or implied, including on packaging, websites, social media and even in the product name.
- By function: the product may be used in, or given to, people with a view to restoring, correcting or modifying physiological functions by a pharmacological, immunological or metabolic action, or to make a medical diagnosis.
So a product sold as a food supplement can still be treated as a medicine if the way it is presented crosses the line. Food law points the same way: the MHRA's guidance notes that a claim that a food prevents, treats or cures human disease is not permitted.
What a UK food supplement label has to show
These are requirements of the law, not a description of any particular product's label. Regulation 6 of the Food Supplements (England) Regulations 2003 says a food supplement must be sold under the name "food supplement" and must be labeled with:
- the name of the category of any vitamin, mineral or other substance that characterizes the product, or an indication of its nature;
- "the portion of the product recommended for daily consumption";
- "a warning not to exceed the stated recommended daily dose";
- a statement that food supplements should not be used as a substitute for a varied diet;
- a statement that the product should be stored out of the reach of young children;
- the amount of any vitamin, mineral or other substance with a nutritional or physiological effect, in numbers, per recommended portion.
For a vitamin or mineral on the UK's reference list, the amount must also be shown as a percentage of its reference value. Our guide to what NRV means on a supplement label explains that percentage.
On top of that, the general food labeling rules in Regulation (EU) No 1169/2011 apply. The FSA's guidance lists the practical items that result, including the business name and address, a list of ingredients with common allergens emphasized, storage instructions and a "use by" or "best before" date. The same regulation 6 also bars labeling, presentation or advertising that suggests a balanced and varied diet cannot provide appropriate quantities of nutrients in general.
Who oversees food supplements in the UK
According to the FSA's guidance, policy and legislative responsibility for food supplements sits with:
- England: the Department of Health and Social Care
- Scotland: Food Standards Scotland
- Wales: the Welsh Government
- Northern Ireland: the Food Standards Agency
The guidance also says anyone selling food supplements must register as a food business operator with their local authority, and that it is the seller's responsibility to make sure the supplements they sell are safe. The MHRA's guidance notes that local authorities enforce the food information rules, and that businesses should check with their local authority's Environmental Health or Trading Standards service that a product complies with food law.
Health claims have their own rulebook. In Great Britain, only claims authorized on the Great Britain nutrition and health claims register may be used.
What "food supplement" does not tell you
- They are not an approval mark. "Food supplement" names the legal category a product is sold in. The FSA's guidance describes duties that fall on the seller, including registration and responsibility for safety.
- They say nothing about effect. The category tells you how a product is regulated, not what it will do for the person taking it.
- They do not tell you whether you need one. NHS guidance says most people should get all the nutrients they need by having a varied and balanced diet, although some people may need to take extra supplements.
- They do not tell you whether a product suits you. If you have any question about whether a food supplement is suitable for you, ask a pharmacist, GP or other qualified professional first.
- They do not tell you what a batch contains. For what a laboratory document can and cannot show, see how to read a certificate of analysis.
Why the words are on our bottle
NAD+ Sublingual Drops are sold as a food supplement, and UK rules require a product sold as a food supplement to carry that name. That is the whole reason the words are there. They are not an approval, and they are not a claim about what the product does.
The list of label requirements earlier in this article describes the regulations in general. It is not a description of our label, and this article gives no serving details for our product. For the biology behind the name on the bottle, see our Science page.
Frequently asked questions
What does "food supplement" mean on a label?
It is the legal name a supplement must be sold under in the UK. It means the product is regulated as a food, not as a medicine.
Is a food supplement a medicine?
No. The FSA's guidance says food supplements are not medicinal products. The MHRA can still treat a product as a medicine if it is presented as treating or preventing disease, or if it functions as one.
Is "dietary supplement" the same thing?
Not on a UK label. The FSA's guidance says a product sold here must be labeled "food supplement", not "dietary supplement".
