Micronutrient dosing limits.

In short: EU law provides the framework, not the numbers

EU law defines the permitted nutrients and forms for food supplements (Directive 2002/46/EC) as well as the reference intakes and the 15% threshold used for labelling (Regulation (EU) No 1169/2011). Harmonised minimum and maximum amounts for food supplements are foreseen in Article 5 of the Directive, but have never been adopted.

The dosing window is therefore Novogenia’s own rule — built on the EU reference intakes and on the safety assessments of the European Food Safety Authority (EFSA).

The dosing window

• Minimum: about one third (30–35%) of the RDA for every included nutrient. That is more than twice the 15% “significant amount” of EU labelling law, which is a labelling threshold and not Novogenia’s minimum.
• Maximum: about 300% of the RDA. It is used only where genetics, lifestyle data or blood values justify a higher dose.
• The RDA (shown on labels as “NRV”) is only the scale on which the window is defined. It is a single value for all adults — neither an individual recommendation nor a limit of what a person may need.

Exceptions

• Vitamin B12: 80–800 µg per day. Only about 1% of a high oral dose is absorbed (roughly 10 µg of 800 µg). EFSA’s adequate intake is 4 µg per day; there is no UL, because no adverse effects of high intakes are known.
• Vitamin D3: 10–50 µg per day (400–2,000 IU). The labelling reference value is 5 µg, whereas EFSA’s adequate intake for adults is 15 µg. The maximum is half of the EFSA UL of 100 µg.
• Lower maxima: magnesium 250 mg and zinc 25 mg (both equal to the EFSA UL), calcium 1,200 mg and copper 2 mg.
• Higher minima: iron 14 mg and manganese 2.5 mg.

Safety ceiling

EFSA’s Tolerable Upper Intake Level (UL) is the maximum chronic daily intake that is not expected to pose a risk of adverse health effects. Novogenia enforces it as a hard limit: for every nutrient with an EFSA UL, Novogenia’s maximum is at or below it.

Minimum and maximum per nutrient

Amounts per day; percentages refer to the RDA. EFSA values for adults from the Overview on Tolerable Upper Intake Levels, Version 11 (August 2025). “Safe level” is EFSA’s safe level of intake, given where no UL could be derived.

How the individual dose is set within the window

• Inputs: about 50 genes per analysis, plus age, sex, body weight, the nutrition and lifestyle questionnaire and, where available, blood values. For each nutrient, the highest resulting requirement counts.
• Priority of data: where blood values are available, they can in some cases take precedence over genetics. A deficiency drives the nutrient to its maximum dose; an excess excludes it, regardless of the genetic result.
• Reference basis: established reference values (D-A-CH / EFSA), peer-reviewed primary literature per SNP, Novogenia’s own PubMed-based literature reviews and the weighting scores derived from them.
• Ingredients without an RDA (omega-3, coenzyme Q10, alpha-lipoic acid, collagen, lutein, MSM, hyaluronic acid, phytosterols) have a fixed minimum and maximum per ingredient — omega-3, for example, is either 0 or 950 mg.
• Identical doses at the limit: because the maximum is a hard limit, two people whose requirement lies above it receive the same maximum value. This is expected and not an error.