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Health claims: what you may say when marketing your food supplement

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 11 October 2026 · Reading time: 11 min

The basic rule: anything not authorized is prohibited

For health-related marketing, EU food law follows a clear principle: only what has been expressly authorized is allowed. The legal basis is Regulation (EC) No 1924/2006 on nutrition and health claims made on foods, known as the Health Claims Regulation. Under Directive 2002/46/EC, food supplements are foods – so the regulation applies to your product too.

Three key points (article numbers without further reference refer to Regulation (EC) No 1924/2006):

• Scope: The regulation applies to claims made in commercial communications, whether in the labeling, presentation or advertising of foods (Article 1(2)). So it covers every advertisement, not just the label.
• Images count too: A “claim” is any message or representation that is not mandatory – expressly including pictorial, graphic or symbolic representations (Article 2(2)(1)).
• Prohibited unless authorized: Health claims are prohibited unless they are authorized and included in the lists of authorized claims (Article 10(1)).

Nutrition, health and disease claims: the difference

In practice:

Where to find the authorized health claims

The European Commission established the list of permitted function claims with Regulation (EU) No 432/2012; it has since been extended with newly authorized claims. You can search it in the Commission’s EU Register of nutrition and health claims. It contains the authorized claims with their conditions of use as well as the non-authorized claims with the reasons for their rejection. The Commission describes the register as information only – legally, the regulations themselves count.

Every authorized claim has a condition of use. For many vitamins and minerals: the claim may be used only for food which is at least a source of the nutrient as defined in the Annex to Regulation (EC) No 1924/2006. Some claims additionally require a specific daily intake – for example the claim on vitamin C and intense physical exercise. Always read the condition, not just the wording.

The condition that is often overlooked: enough of the nutrient

A health claim is only permitted if the nutrient is contained in the final product in a significant quantity as defined in EU legislation, and if the quantity of the product that can reasonably be expected to be consumed provides that significant quantity (Article 5(1)(b) and (d)). Where no such rules exist, the amount must be one that will produce the claimed effect according to generally accepted scientific evidence.

For vitamins and minerals, Annex XIII of Regulation (EU) No 1169/2011 gives as a rule 15% of the nutrient reference value (NRV) as the guide value for a significant amount. To claim that a product is “high” in a vitamin or mineral, the Annex to the Health Claims Regulation requires at least twice the value for “source of”. For food supplements, nutrient amounts are declared per portion recommended for daily consumption (Article 8 of Directive 2002/46/EC).

Practical tip: Plan dosage and claims together. Otherwise you may find that a nutrient is dosed too low for the claim you want – or that no claim is authorized for an ingredient you included. Dosage is also capped by safety values; see Micronutrient dosing limits.

How much freedom do you have with the wording?

You do not always have to copy the authorized wording letter for letter: according to recital 9 of Regulation (EU) No 432/2012, a claim that has the same meaning for consumers as an authorized claim is subject to the same conditions of use. But any rewording must keep the same meaning. If “contributes to the normal function” turns into “boosts”, “enhances” or “protects”, you risk leaving the authorized scope.

Two more rules concern the form:

• General well-being statements only with a companion claim: References to general, non-specific benefits for overall good health or health-related well-being may only be made if accompanied by a specific authorized health claim (Article 10(3)).
• Mandatory information: Health claims require a statement on the importance of a varied and balanced diet and a healthy lifestyle, the quantity and pattern of consumption needed for the claimed effect, where appropriate a statement for people who should avoid the product, and a warning if excess consumption is likely to present a health risk (Article 10(2)).

Examples: compliant or risky?

Generic examples; the left column assumes that your product meets the conditions of use, for example that it contains enough of the nutrient.

What is always prohibited

• Disease claims: Food information must not attribute to any food the property of preventing, treating or curing a human disease, nor refer to such properties – expressly including advertising (Article 7(3) and (4) of Regulation (EU) No 1169/2011). For food supplements, the same prohibition is in Article 6(2) of Directive 2002/46/EC.
• Article 12 restrictions: Claims which suggest that health could be affected by not consuming the food, claims about the rate or amount of weight loss, and references to recommendations of individual doctors or health professionals.
• Doubting a normal diet: Statements that a balanced and varied diet cannot provide appropriate quantities of nutrients in general (Article 3(d); Article 7 of Directive 2002/46/EC).
• Misleading claims, excess, fear: Claims that are false, ambiguous or misleading, encourage excess consumption or exploit fear about changes in bodily functions (Article 3(a), (c) and (e)).

A special case: botanical “on hold” claims

For many claims on plant substances, known as botanicals, the scientific evaluation has not been completed, and there is no list of authorized claims for them so far. According to the recitals of Regulation (EU) No 432/2012, claims whose evaluation has not been completed may continue to be used under the transitional measures in Article 28(5) and (6) of Regulation (EC) No 1924/2006 – under the responsibility of the business.

But the room for maneuver is small: in 2025, the Court of Justice of the European Union ruled (Case C-386/23) that until the Commission has completed its examination, specific health claims on botanicals referring to psychological or behavioral functions may not be used unless Article 28(6) permits it. General references to health and well-being also need a specific claim from the authorized lists alongside them. Have botanical marketing reviewed case by case.

Website, social media and influencers

The regulation covers claims in labeling, presentation and advertising. On social media, problems often arise in videos, story captions or replies to comments rather than in the planned post. Product names count too: a trade mark, brand name or fancy name that may be construed as a health claim may only be used if it is accompanied by a compliant claim (Article 1(3)).

Whoever sells a supplement under their own name is responsible for its advertising. To stay in control:

• Give everyone who promotes your product – team, agency, influencers, sales partners – a list of the wording they may use.
• Review posts before they go live – including images, graphics and symbols.
• Label customer reviews clearly as customer opinions. In your own review system, remove reviews with unauthorized efficacy claims and correct clearly false statements in a reply.

Personalized and gene-based products: never promise a diagnosis

With personalized supplements, you also describe how the formula is created. Two principles from Novogenia’s experience:

• Describe the analysis, do not diagnose: You can state factually that a formula is calculated from genetic, blood or questionnaire data. But advertising for the supplement must not create the impression that it detects or treats a disease.
• Label gene-based adjustments as logical conclusions: That certain genes influence how the body handles particular nutrients is supported by studies for each of those genes. That a dosage adjustment derived from this achieves a specific effect has not been confirmed by randomized, placebo-controlled studies for all genetic effects. So call such adjustments logical conclusions and add a disclaimer.

* A suitable disclaimer explains, in essence: the genetic traits determined are supported by studies; the dosage adjustments derived from them have not yet been confirmed by randomized, placebo-controlled studies for all genetic effects and should therefore be understood as logical conclusions. For the nutrients themselves, only the authorized health claims still apply. More in Manufacturing personalized supplements.

Checklist before you publish

• Every health-related statement matches an authorized claim – word for word or with the same meaning.
• The conditions of use are met, above all the significant amount of the nutrient.
• The mandatory information under Article 10(2) is included.
• Not a word about preventing, treating or curing disease – not in images or testimonials either.
• General well-being statements appear only together with an authorized claim.
• No claims about the rate or amount of weight loss, no recommendations by individual doctors.
• Gene-based recommendations are labeled as logical conclusions with a disclaimer; customer reviews are labeled as opinions.
• A second person has read the copy with a critical eye – if in doubt, a qualified expert.

For the other mandatory label information, see Labeling: mandatory information.

Frequently asked questions

Related: Labeling: mandatory information · Micronutrient dosing limits · Manufacturing personalized supplements

Note: This guide is general information and does not constitute legal advice. Regulations can change; errors and changes excepted. Always have legal questions about your specific product checked by a qualified expert.