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Dosing and safety: EFSA upper levels and maximum amounts in Germany, Austria and Switzerland

Reviewed by Dr. Daniel Wallerstorfer, molecular biologist and founder of Novogenia · Updated: 13 October 2026 · Reading time: 10 min

In short

The rule for personalized supplements: as much as needed, never more than is safe. At Novogenia, every dose lies between about one third and three times the reference intake and at or below EFSA’s tolerable upper intake level – iron, for example, at no more than 40 mg. There are no EU-wide maximum amounts for food supplements; Germany and Austria have no statutory maximum amounts, although Germany’s BfR publishes recommendations. Switzerland sets binding maximum amounts per daily serving, some of them well below EFSA’s values.

Iron: where even EFSA cannot derive an upper level

For iron, the European Food Safety Authority (EFSA) could not derive a tolerable upper intake level – the data were insufficient. Instead, it gives a safe level of intake: 40 mg per day for adults, including during pregnancy and breastfeeding. That is exactly where Novogenia’s maximum for iron lies.

Mathematically, the window would allow more: the reference intake for iron is 14 mg, and three times that would be 42 mg. The upper limit cuts off the peak. This shows the core principle of this article: with micronutrients, more is not automatically better. For many of them, risk follows a U-shaped curve – too little is unfavorable, and so is too much. Examples include iron, vitamin A, selenium, the balance between zinc and copper, and folic acid, which can mask a vitamin B12 deficiency. Personalization therefore means: as much as needed, never more than is safe. Here you will learn which limits apply – scientifically, in the EU, in Germany, in Austria and in Switzerland.

The benchmark: EFSA’s upper levels

The tolerable upper intake level (UL) is the maximum level of total chronic daily intake of a nutrient from all sources that is not expected to pose a risk of adverse health effects. EFSA compiles all values in an overview of tolerable upper intake levels, most recently in version 11 of August 2025. Three details matter for you:

Total intake: As a rule, the UL covers everything a person takes in – food, fortified foods and food supplements combined.
Exceptions: For magnesium, the UL applies only to readily dissociable magnesium salts and compounds such as magnesium oxide, for example in food supplements, not to magnesium naturally present in foods. For folate, it applies only to added forms such as folic acid and methylfolate.
Safe level of intake: Where the data are insufficient for a UL, EFSA sometimes gives a safe level of intake, for example for iron and manganese. Intake above it does not automatically mean a risk.

Nutrient	EFSA, adults	Novogenia maximum
Vitamin D	UL 100 µg	100 µg
Vitamin B6	UL 12 mg	4.3 mg
Folate	UL 1,000 µg (added forms)	600 µg
Selenium	UL 255 µg	165 µg
Zinc	UL 25 mg	25 mg
Magnesium	UL 250 mg (added forms)	250 mg
Calcium	UL 2,500 mg	1,200 mg
Iron	no UL; safe level of intake 40 mg	40 mg

Because the UL usually refers to total intake, one question belongs in every process: what else does the customer take? Other food supplements add to the formula.

The window: one third to three times

Within these upper levels, Novogenia works with a fixed window. The scale is the reference intakes set by EU labeling law (Annex XIII of Regulation (EU) No 1169/2011). They are a single value for all adults – not a personal recommendation, just the scale on which the window is defined:

Minimum: about one third of the reference intake for every nutrient included.
Maximum: about three times the reference intake, used only where genetics, lifestyle data or blood values justify it.
Exceptions above: vitamin D3 (10 to 100 µg) and vitamin B12 (80 to 800 µg); only about 1% of a high oral dose of vitamin B12 is absorbed.
Exceptions below: magnesium (250 mg) and zinc (25 mg) end at the UL, calcium at 1,200 mg and copper at 2 mg.
No reference intake: omega-3, coenzyme Q10, alpha-lipoic acid, collagen, lutein, MSM, hyaluronic acid and phytosterols each have a fixed minimum and maximum.

A calculated requirement below the minimum is set to the minimum, and one above the maximum is set to the maximum. Two people with a very high requirement therefore receive the same dose – that is intended. The full table is on Micronutrient dosing limits; how a brand sets its own dosing rules is explained in Developing a formula.

Important for you as a data owner: the window is applied anew for every production run – with the current age and with new blood values, genetic data or questionnaire answers. New data can shift a dose, but never push it out of the window.

EU: maximum amounts foreseen, but never set

Article 5 of Directive 2002/46/EC provides for maximum amounts of vitamins and minerals in food supplements, per daily portion recommended by the manufacturer. They are to take into account upper safe levels established by scientific risk assessment and intake from other sources. To this day they have not been set: according to the European Commission, no proposal has been presented yet because of the complexity of the issue and divergent views.

Two things are binding all the same. First, the basic rule of food safety: food shall not be placed on the market if it is unsafe (Article 14 of Regulation (EC) No 178/2002). Second, labeling: every food supplement states the recommended daily portion and carries a warning not to exceed it (Article 6(3) of the Directive). A reputable manufacturer therefore needs its own transparent dosing rules – ask to see them.

Germany: no statutory maximum amounts, but BfR recommendations

The German Food Supplements Ordinance (NemV, in German) regulates which nutrients may be used in which forms (Section 3), what goes on the label (Section 4) and that a product must be notified to the Federal Office of Consumer Protection and Food Safety (BVL) (Section 5). It contains no statutory maximum amounts for vitamins and minerals.

The German Federal Institute for Risk Assessment (BfR), however, has published proposed maximum amounts per recommended daily dose of a product, since 2021 for people aged 15 and over. They take into account EFSA’s upper levels, the reference values for nutrient intake and the amounts people already take in through their usual diet. That is why, for some nutrients, they are well below EFSA’s values. The proposals are recommendations from a government agency, not law. Anyone selling in Germany should nevertheless know them and align their positioning with experts.

Austria: an ordinance without maximum amounts

The Austrian Food Supplements Ordinance (NEMV, Federal Law Gazette II No. 88/2004, in German) transposes the EU Directive. It lists the permitted vitamins and minerals and their forms (Section 2), requires among other things the recommended daily dose and a warning not to exceed it (Section 3), and the amount per daily dose (Section 5). It contains no maximum amounts either. The general obligation to place only safe food on the market applies. As in Germany, the manufacturer’s dosing rules are therefore what counts.

Switzerland: binding maximum amounts per daily serving

Switzerland takes its own path. The FDHA Ordinance on Food Supplements (VNem, SR 817.022.14, in German) sets binding maximum amounts for adults in Annex 1 that must not be exceeded per recommended daily serving (Art. 2(5) VNem; consolidated version as of 1 February 2024). An excerpt for comparison:

Nutrient	EFSA, adults (total intake)	Switzerland, VNem (per daily serving)
Vitamin D	100 µg	70 µg
Folate or folic acid	1,000 µg (added forms)	750 µg
Vitamin B6	12 mg	15 mg
Iron	40 mg (safe level of intake)	21 mg
Zinc	25 mg	5.3 mg
Selenium	255 µg	165 µg
Magnesium	250 mg (added forms)	375 mg
Calcium	2,500 mg	750 mg

The key differences from the EU, Germany and Austria:

Law instead of a gap: The EU lacks harmonized maximum amounts, and Germany and Austria lack national ones. In Switzerland, they are binding.
Per product, not per person: The VNem caps the daily serving of a product; EFSA’s UL describes a person’s total intake from all sources.
Sometimes stricter, sometimes more generous: For vitamin D, folic acid, iron, selenium and calcium, the Swiss values are below EFSA’s, and for zinc markedly so. For magnesium and vitamin B6, they are higher.
Vitamin A only as beta-carotene: at most 1,360 µg retinol equivalents per daily serving, corresponding to 8.2 mg of beta-carotene.
Warnings tied to amounts: Above 250 mg of magnesium per day, for example, a warning that magnesium preparations can have a laxative effect is mandatory.
Ongoing updates: The Federal Food Safety and Veterinary Office (FSVO) adapts the annexes to the state of science and technology and to the law of Switzerland’s main trading partners (Art. 6 VNem).

For a personalized formula, this means: for customers in Switzerland, the VNem caps the dosing window further – for zinc, for example, at 5.3 mg instead of 25 mg. Novogenia complies with national statutory maximum amounts. So clarify early in the project which countries you will ship to. Switzerland also has its own rules for the genetic analysis itself; more in From genetic data to a formula.

Medications, pregnancy, interactions

Upper levels protect the population as a whole; individual situations need more. With medical conditions, medications, pregnancy and breastfeeding, the question of supplementation belongs in a physician’s hands, as it does with abnormal blood values. Swiss law makes this visible with an example: from 25 µg of vitamin K per day, the VNem requires a note that people taking anticoagulant medication should consult their physician first.

Interactions between nutrients – for example between calcium and iron, or between zinc and copper, which compete for the same absorption routes – can be resolved in a formula by releasing them at different times; details in Developing a formula. What matters most for you as a lab or platform: define how cases involving medications, pregnancy or abnormal values are identified and referred to a physician. How blood values feed into the formula is shown in From blood values to a formula.

Checklist: safety in your project

The manufacturer’s dosing rules are disclosed: minimum, maximum, exceptions and upper limit per nutrient.
Every maximum is at or below EFSA’s upper level or safe level of intake.
Your target countries are defined and their requirements checked – in Switzerland the binding VNem maximum amounts, in Germany the BfR recommendations.
Your customers are asked about any other food supplements they take.
Medications, pregnancy, breastfeeding and abnormal blood values lead to a medical work-up.
Label and leaflet state the recommended daily dose and the warning not to exceed it.
New blood values or questionnaire answers flow into the next production run – within the same window.

How we do it at Novogenia

How we safeguard dosing at Novogenia:

Window: at least about one third, at most about three times the reference intake; the maximum is used only where genetics, lifestyle data or blood values justify it.
Documented exceptions: vitamin D3 and vitamin B12 go above the range; magnesium, zinc, calcium and copper stay below it; iron and manganese have a higher minimum.
Hard ceiling: For every nutrient with an EFSA tolerable upper intake level, our maximum is at or below that value; for iron it is 40 mg, EFSA’s safe level of intake.
National maximum amounts: are complied with as well – even where studies would suggest that a higher dose could be beneficial.
Capping rule: A requirement outside the window is set to the minimum or maximum; values outside the window are never produced.
Recalculated: for every production run, at least with the current age, plus new questionnaire, blood or genetic data.
Published: All minimum and maximum amounts per nutrient are listed on our page on micronutrient dosing limits.

Frequently asked questions

What is a tolerable upper intake level (UL)?

The maximum level of total chronic daily intake of a nutrient from all sources that, according to EFSA, is not expected to pose a risk of adverse health effects. Where the data are insufficient for a UL, EFSA gives a safe level of intake – for iron, 40 mg per day for adults.

Are there statutory maximum amounts for food supplements in the EU?

Not EU-wide. Article 5 of Directive 2002/46/EC provides for them, but the European Commission has not yet presented a proposal. Germany and Austria have no statutory maximum amounts of their own; in Germany, the BfR publishes recommendations. Switzerland sets binding maximum amounts.

What do the Swiss maximum amounts mean for a personalized formula?

They apply per recommended daily serving and are binding. For customers in Switzerland, they cap the dosing window further – for example zinc at 5.3 mg, iron at 21 mg and vitamin D at 70 µg per day. Vitamin A is permitted there only as beta-carotene.

Can a personalized formula be overdosed?

Not within the formula: every dose stays inside the window and at or below EFSA’s upper level, and national statutory maximum amounts apply on top. But because the UL usually refers to total intake, you should ask your customers about any other food supplements they take.

What applies with medications, pregnancy and breastfeeding?

Then the question of supplementation belongs in a physician’s hands – as it does with medical conditions and abnormal blood values. Define in your process how such cases are identified and referred to a physician.

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Note: This guide is general information for businesses and professionals and does not replace medical or legal advice. The genetic traits determined in a genetic analysis are well documented (each gene included is backed by at least three independent studies); recommendations derived from them are logical conclusions, not scientifically proven. Regulations can change; errors and changes excepted.