Food vs. Dietary Supplement

Key differences and what they mean for your brand.

August 29, 2023

When you're in the food and beverage industry, understanding the difference between conventional foods and dietary supplements is crucial. But how exactly does it impact your brand?

For starters, the classification of your product as either a food or a dietary supplement significantly impacts the regulatory requirements that apply, including standards for product labeling, manufacturing, and FDA notification. So, let's dig a little deeper.

Conventional foods include items like beverages, drinks, and other products that typically use conventional food terms on their labels and are intended to be consumed as foods. 

On the other hand, dietary supplements are products consumed orally, containing dietary ingredients intended to supplement the diet. These ingredients can range from vitamins, minerals, amino acids to herbs or botanicals. Dietary supplements can take many forms, including tablets, capsules, soft gels, gel caps, liquids, or powders.

Conventional foods and dietary supplements follow independent regulatory frameworks with distinct requirements. Here’s a snapshot of the key differences between foods and dietary supplements:

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Packaging, serving size, composition, and product name are some of the factors that influence this classification.

For example: let's say you have a powdered botanical product named “Herbal Tea,” with a single serving size of 8 ounces, packaged in an aluminum can. This product would likely be classified as a food. But change the serving size to "4 capsules” and market it in a plastic bottle with a child-resistant cap, your product looks a lot more like a dietary supplement.

As a brand, you're responsible for making this critical decision. It's not just a matter of semantics—the way you position your product will directly influence the rules and regulations your product must follow. Keeping your product within the correct regulatory framework is essential for its success and your brand's reputation.

So, keep in mind: the difference between conventional foods and dietary supplements is more than just a label - it's an important decision that affects your product's journey from production to consumer.

So is my product a food or a dietary supplement?

Classification depends on overall product position and can turn on many factors, including packaging, serving size, composition, and product name.

For example: let's say you produce a powdered botanical drink mix product called “Herbal Tea,” with a single serving size of 8 fluid ounces once mixed with water. This product would likely be classified as a food. But change the serving size and format to "4 capsules” and market it in a plastic bottle with a child-resistant cap, your product looks a lot more like a dietary supplement.

Beyond the product format, serving size and market positioning, sometimes the ingredient composition alone can determine the classification of a product.  For instance, ingredients like melatonin, rhodiola, and St. John’s Wort are only allowed in dietary supplements, but not conventional foods.  

As a brand, you're responsible for making this critical decision, and the way you position your product will directly influence the rules and regulations your product must follow.  Assessing which classification is best suited for your product is one of the first steps we suggest exploring in the go-to-market process.  Doing so early in the process, will ultimately help determine the subsequent go-to-market steps and partners including contract manufacturer qualification and selection, label design, claim substantiation and market positioning, retailer-readiness, and overall brand communications.

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