What should you look for in 3 types of food supplement?

One definition, three rulebooks: how the law defines a food supplement, why it then treats three types differently, and the first type, vitamins and minerals, with its positive list, its reference values and its two reads

What should you look for in the three types of food supplement is a question that the shelf answers with marketing categories, sport, wellness, beauty, and the law answers with three rulebooks, which are the ones worth knowing because they decide what a label must say and what a buyer can check. The UK regulations define a food supplement as a food whose purpose is to supplement the normal diet, which is a concentrated source of nutrients or other substances with a nutritional or physiological effect, alone or in combination, sold in dose form, capsules, tablets, sachets, measured liquids and the like. That definition is one, and it covers everything on the shelf that is not a medicine; but the rules that follow treat three types of substance differently, and the type decides what the buyer looks for.

The first type is vitamins and minerals, and it has the fullest rulebook. The regulations carry a positive list: only the vitamins and minerals named may be used, and only in the chemical forms the list permits, so that a magnesium may be a citrate, an oxide, a bisglycinate or any of the other listed forms and may not be a form that is not listed, and a brand that invents a form has sold something outside the law. The label must declare each vitamin and mineral per daily dose as recommended on the label and as a percentage of the nutrient reference value, so that a buyer can read a dose against the population's reference in one glance. And the register of authorised health claims carries the fullest set of claims for this type, assessed nutrient by nutrient, so that a magnesium's label may say normal muscle function and may not say sleep. The two reads for type one are therefore the form against the list, which the ingredient list shows, and the dose against the reference value and the upper level, which the nutrition panel shows; a buyer who reads those two has read a type-one supplement in full.

The type matters because the shelf blurs it: a product that mixes a listed mineral with a botanical and an amino acid is three types in one tub, and each is read by its own rulebook, which the next section takes in turn for types two and three.

One definition and the first rulebook set out, with the second type and its claims and tolerance, the third type and its medicines border, the mixed tub, the worked example read against its rulebook and the verdict in the next section.

The second type, other nutritional substances, with its claims and its tolerance; the third type, botanicals, with its missing list, its on-hold claims and its medicines border; the mixed tub; the worked example; and the verdict

The second type is the other nutritional substances: the amino acids and their derivatives, the fatty acids, creatine, carnitine, fibre, the probiotics, and the other substances with a nutritional or physiological effect that are not vitamins, minerals or plants. This type has no positive list, so any such substance may be used provided it is safe and not a medicine, and the buyer cannot check a form against a list because there is none. What the type does have is authorised claims for some substances, creatine's claim for physical performance in short bursts, the omega-3 claims for heart function and triglycerides, protein's claims for muscle mass, and a tolerance on the declared amount, the band within which the measured content of a batch may differ from the label and still be lawful, which the labelling guidance sets. The two reads for type two are the claim against the register, since a type-two substance with no authorised claim is sold on a pitch, and the amount against the tolerance, which a certificate of analysis for the finished product shows and the label alone does not; a buyer who wants to know whether the creatine in the tub is the creatine on the label asks for that document.

The third type is the botanicals: the plant extracts, herbs and fungi, from turmeric and ashwagandha to the mushroom powders. This type has no positive list, so any plant may be used that is not prohibited, and it has almost no authorised claims, because the register's assessment of botanical claims was put on hold and most remain unassessed, so that a botanical label in the UK may make almost no health claim at all and the pitch is made by the brand name and the picture. The third type also sits on the border with medicines: a botanical that acts on the body as a medicine does, or that has a history of medicinal use, may be a medicine in the regulator's eyes whatever the tub calls it, and some are sold as supplements that the regulator treats as borderline or unlicensed medicines. The reads for type three are therefore different in kind: the plant part, because root and leaf are different products; the extract ratio and the solvent, which decide how concentrated the extract is; the standardisation, which names the compound the extract is standardised to and at what percentage, without which the dose means nothing; and the medicines border, which a buyer reads by checking the regulator's lists and by asking a pharmacist about any botanical taken alongside a medicine, since the herb-drug interactions and the liver records live in this type.

A mixed tub is read by all three rulebooks, one ingredient at a time, and a buyer who finds that it cannot be read, because the botanical has no standardisation, the amino acid has no amount, or the mineral is in an unlisted form, has read it after all. The worked example is a type-one supplement read against its rulebook: {FL} is magnesium bisglycinate, a form on the permitted list, declared as 1500mg bisglycinate providing 300mg elemental at 80% of the nutrient reference value per daily dose of two capsules, with authorised claims for normal muscle function, normal psychological function and the reduction of tiredness and fatigue, and no claim outside the register; the two other ingredients, the HPMC capsule shell and rice flour, are excipients and not supplements of any type. It is batch tested for lead, mercury, arsenic and cadmium, UK made under GMP and BRC, 180 capsules for £19.99 at 22p a day. The full label breakdown is here.

The verdict: one definition and three rulebooks. For vitamins and minerals, look for the form against the positive list and the dose against the reference value and the upper level. For the other nutritional substances, amino acids, fatty acids, creatine and the rest, look for the claim against the register and the amount against the tolerance, with a finished-product certificate for the second. For botanicals, look for the plant part, the extract ratio, the standardisation and the medicines border, and ask a pharmacist about any botanical taken alongside a medicine. A mixed tub is read one ingredient at a time, and a tub that cannot be read has been read.

What to check on the label

Questions people also ask

What are the three types of food supplement?

The three types the UK regulations treat differently under one definition: vitamins and minerals, which have a positive list of permitted forms, must be declared per daily dose and as a percentage of the reference value and carry the fullest set of authorised claims; the other nutritional substances, amino acids, fatty acids, creatine, carnitine, fibre and probiotics, which have no positive list but hold authorised claims for some and are held to a tolerance on their declared amount; and the botanicals, which have no positive list, almost no authorised claims because the register put them on hold, and a border with medicines; the type decides what the buyer reads on the label.

What is the legal definition of a food supplement in the UK?

A food whose purpose is to supplement the normal diet and which is a concentrated source of nutrients or other substances with a nutritional or physiological effect, alone or in combination, marketed in dose form such as capsules, tablets, sachets or measured liquids, which is the definition in the regulations that treat supplements as foods rather than medicines; the definition is one, and the rules that follow it give vitamins and minerals a positive list and reference values, the other nutritional substances claims and a tolerance, and the botanicals a prohibition list and a medicines border.

Are herbal supplements regulated the same as vitamins?

Under the same definition and a thinner rulebook: a vitamin or mineral may be used only in a form on the positive list, must be declared against a reference value and may carry the authorised claims the register holds for it, while a botanical may be any plant not prohibited, is declared by amount with no reference value, may carry almost no health claim because the register's assessment of botanical claims was put on hold, and sits on the border with medicines, so that a plant which acts or has a history as a medicine may be treated as one by the regulator; a buyer reads a botanical for its plant part, extract ratio, standardisation and interactions rather than for a form and a reference value.

How do I know the dose of a botanical supplement is real?

By three things the label must give for the dose to mean anything: the plant part, because root, leaf and fruit of the same plant are different products; the extract ratio and solvent, which state how many parts of raw plant made one part of extract and in what; and the standardisation, which names the compound the extract is standardised to and at what percentage, so that a turmeric extract standardised to a stated percentage of curcuminoids has a readable dose and one that says only turmeric extract does not; with those three a buyer can compare products, and without them the milligram figure on the front is the weight of a powder, not a dose of anything.

Which type of food supplement is this site's magnesium?

Type one, a mineral, read against the fullest rulebook: magnesium bisglycinate is a form on the permitted list, it is declared as 1500mg bisglycinate providing 300mg elemental magnesium at 80% of the nutrient reference value per daily dose of two capsules, and its claims for normal muscle function, normal psychological function and the reduction of tiredness and fatigue come from the register, with the two other ingredients, the HPMC capsule shell and rice flour, being excipients rather than supplements of any type; it is batch tested for four metals, UK made under GMP and BRC, 180 for £19.99 at 22p a day.

Sources

1. The Food Supplements (England) Regulations 2003 (food supplements are regulated as foods in the UK). https://www.legislation.gov.uk/uksi/2003/1387/contents/made
2. Retained Regulation (EC) No 1924/2006 on nutrition and health claims made on foods, and the Great Britain nutrition and health claims register. https://www.gov.uk/government/publications/great-britain-nutrition-and-health-claims-nhc-register
3. The MHRA's borderline guidance: a product is a medicine if it is presented as treating or preventing disease or has a significant pharmacological, immunological or metabolic action, determined case by case on presentation and function. https://www.gov.uk/government/publications/a-guide-to-what-is-a-medicinal-product
4. The vitamin and mineral form literature: magnesium oxide has lower fractional absorption than citrate or glycinate; synthetic DL-alpha-tocopherol has about half the biological activity of the natural RRR form per milligram; cyanocobalamin and methylcobalamin both correct B12 deficiency; form changes absorption or activity per milligram rather than whether a nutrient works. PubMed record

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