Six things sellers get wrong on a Supplement Facts panel

Updated 2026-08-24

The panel is a regulation, not a design choice

The nutrition label for a dietary supplement is called a Supplement Facts panel. That is 21 CFR 101.36. A bottle that carries Nutrition Facts instead, because the printer had that template, is already misbranded as a supplement.

Amazon main images that crop the panel, or replace it with a marketing table, do not replace the pack. FDA collects samples of the actual label. The listing photograph still has to match what is on the bottle, or the entry and the catalogue start to tell two stories.

Mistake one and two: identity, and the wrong panel

The statement of identity on the principal display panel must include the term “dietary supplement,” except that “dietary” may be replaced with a description of the dietary ingredients, such as “herbal supplement.” Brand names are not the statement of identity and should not dwarf it.

Using a food Nutrition Facts box on a capsule product is the second mistake. The formats are not interchangeable. Type size, hairlines, the title “Supplement Facts,” and the way (b)(2) dietary ingredients are listed are all specified in 21 CFR 101.36(e).

Mistake three and four: proprietary blends, and missing other ingredients

A proprietary blend is listed by the total weight of the blend. The ingredients inside it are listed in descending order by weight. You do not get to hide the fact that the blend exists, and you do not get to skip the order.

Ingredients that are not dietary ingredients, the capsule shell, fillers, colours, preservatives, still belong on the label. If they are not in the Supplement Facts panel they go in an ingredient statement. 21 CFR 101.36(d) lets you drop a separate ingredient statement only when every ingredient already appears in the panel.

Mistake five and six: the disclaimer, and an old nutrient list

If the label or the listing makes a structure/function claim, the statutory disclaimer has to appear. A panel that is otherwise perfect does not carry that disclaimer for you.

The 2016 revision of the nutrition and supplement labelling rules changed which (b)(2) dietary ingredients must appear. Vitamin D and potassium were added to the mandatory (b)(2) list; vitamin A and vitamin C are no longer required as (b)(2) dietary ingredients unless they are added or a claim is made. Packs still printed to the old list are out of date.

What a label review covers

Label review is $349 per SKU, returned in three business days. It reads required elements and claim risk on the pack you actually print, not a mock-up that never reaches the line. Amazon claim review of the listing is a separate $249 if the problem is the page rather than the bottle.

Common questions

Can I use Nutrition Facts if the product is a gummy that also has calories?

If it is a dietary supplement, 21 CFR 101.36 still governs. Calories, when required, appear inside Supplement Facts, not by swapping in a food panel.

Do I need an ingredient list if everything is in Supplement Facts?

No, not if every ingredient already appears in the panel. If the shell, the flavour or a preservative is missing from the panel, you need the ingredient statement.

Is a serving size of “1 scoop” enough?

The serving size has to match the directions for use and be declared in household measure plus the metric amount the rule requires. A serving that only exists in the marketing copy is not a serving size.

Does FDA approve the panel before I print?

No. FDA does not approve individual food labels, including Supplement Facts. The panel still has to comply.

Will Amazon accept a photograph of a Chinese-language panel?

The US product has to bear the English labeling required by FDA. A photograph of a Chinese export pack is not that label.

Sources

• FDA, Dietary Supplement Labeling Guide, Chapter IV — Supplement Facts under 21 CFR 101.36 — fda.gov
• FDA, Dietary Supplement Labeling Guide, Chapter II — statement of identity must include “dietary supplement” — fda.gov
• FDA, Dietary Supplement Labeling Guide, Chapter V — ingredient statement and 21 CFR 101.36(d) — fda.gov
• FDA, Food Labeling: Revision of the Nutrition and Supplement Facts Labels, small-entity guide — (b)(2) nutrient changes — fda.gov
• FDA, Is It Really 'FDA Approved'? — FDA does not approve individual food labels — fda.gov

This guide is general information about Supplement Facts rules, not legal advice, and it does not create a client relationship. Confirm the panel on your own pack against 21 CFR 101.36 before you print.