Supplement Facts Panel: How to Build a Compliant Dietary Supplement Label

The Supplement Facts panel is the most regulated element of your dietary supplement label—and for good reason. This standardized table communicates what's in your product, how much of each ingredient it contains, and how those amounts relate to daily nutritional needs.

Get it wrong, and you risk FDA warning letters, product recalls, or being unable to work with reputable manufacturers. Get it right, and you've built the foundation for a compliant, trustworthy product.

This guide walks you through every component of a compliant Supplement Facts panel, from serving size declarations to footnote requirements. Whether you're launching your first multivitamin or adding a new SKU to an existing line, you'll learn exactly what the FDA requires and how to format your label correctly.

What Is a Supplement Facts Panel?

The Supplement Facts panel is a mandatory label element for all dietary supplements sold in the United States. It's governed by 21 CFR 101.36, which establishes specific formatting, content, and design requirements.

Unlike food products that use a Nutrition Facts panel, dietary supplements must use the Supplement Facts format. This distinction matters because the two panels have different requirements for:

• Which nutrients must be listed
• How ingredients are grouped and ordered
• What reference values to use (Daily Value vs. RDI)
• How proprietary blends can be displayed
• Formatting and type size specifications

The Supplement Facts panel serves three primary purposes:

1. Transparency: Consumers see exactly what and how much they're getting per serving
2. Safety: Healthcare providers can identify potential interactions or contraindications
3. Compliance: Manufacturers demonstrate adherence to FDA regulations

Step 1: Declare Your Serving Size

The serving size appears at the top of your Supplement Facts panel and establishes the basis for all other declarations.

How to Determine Serving Size

Unlike food products, dietary supplements don't have Reference Amounts Customarily Consumed (RACCs). You determine your own serving size based on:

• Recommended daily intake: What amount delivers the intended benefit?
• Dosage form: Is it a capsule, tablet, powder, liquid, or gummy?
• Label directions: Your serving size must match your directions for use
• Container contents: Total servings should be realistic for the package size

Formatting Requirements

Correct format:

• "Serving Size: 2 Capsules"
• "Serving Size: 1 Scoop (5g)"
• "Serving Size: 2 Gummies"
• "Serving Size: 1 Tablet"

Include weight for powders and liquids:

• Powders: Include gram weight in parentheses
• Liquids: Include milliliter volume in parentheses

Declare servings per container: Immediately below serving size, state: "Servings Per Container: [number]"

If the number of servings varies (like with a powder), you can state "Servings Per Container: About 30"

Pro Tip

Your serving size should align with how consumers will actually use the product. If your capsules are small enough that a typical dose is 3 capsules, don't declare a serving size of 1 capsule just to make the numbers look better. This creates confusion and potential compliance issues.

Step 2: List Dietary Ingredients in the Correct Order

The FDA has strict requirements for how ingredients appear in your Supplement Facts panel. The order matters.

Mandatory Nutrients (If Present)

If your supplement contains any of these nutrients, they must be listed first, in this exact order:

1. Calories (if 5 or more per serving)
2. Total Fat
3. Saturated Fat
4. Trans Fat
5. Polyunsaturated Fat
6. Monounsaturated Fat
7. Cholesterol
8. Sodium
9. Total Carbohydrate
10. Dietary Fiber
11. Total Sugars
12. Added Sugars
13. Protein
14. Vitamin D
15. Calcium
16. Iron
17. Potassium

Vitamins and Minerals

After mandatory nutrients, list other vitamins and minerals. These can appear in any order, but most brands use alphabetical order for clarity.

For each vitamin or mineral, you must declare:

• Amount per serving: In the appropriate unit (mg, mcg, IU)
• % Daily Value: Calculated using the Daily Value (DV) established in 21 CFR 101.9

Example:

Vitamin C (as Ascorbic Acid)     90 mg     100%
Vitamin E (as d-alpha Tocopherol) 15 mg     100%
Thiamin (Vitamin B1)              1.2 mg    100%

Source Ingredients in Parentheses

Always identify the source or form of each nutrient in parentheses:

• "Calcium (as Calcium Carbonate)"
• "Magnesium (from Magnesium Oxide)"
• "Vitamin B12 (as Methylcobalamin)"

This is required information and helps consumers understand the specific forms used.

Dietary Ingredients Without Daily Values

Many supplement ingredients don't have established Daily Values. These include:

• Botanical ingredients (herbs, plant extracts)
• Amino acids
• Enzymes
• Specialty ingredients (CoQ10, resveratrol, etc.)

For these ingredients:

• List the amount per serving
• Include the plant part if botanical (root, leaf, seed)
• Use a dagger (†) or asterisk (*) to indicate "Daily Value not established"
• Place these after vitamins and minerals

Example:

Turmeric Root Extract              500 mg    †
Ashwagandha Root (Withania somnifera) 300 mg †
L-Theanine                         200 mg    †

† Daily Value not established

Step 3: Handle Proprietary Blends Correctly

Proprietary blends allow you to group multiple ingredients under a single weight declaration without revealing individual amounts. This protects your formula while maintaining compliance.

When You Can Use a Proprietary Blend

You may use a proprietary blend for:

• Botanical ingredients
• Amino acids
• Other dietary ingredients without Daily Values

You cannot include vitamins or minerals with established Daily Values in a proprietary blend.

Formatting Requirements

1. Give the blend a descriptive name ("Energy Support Blend", "Cognitive Complex")
2. Declare the total weight of the blend
3. List all ingredients in descending order by weight
4. Include source information for each ingredient
5. Add the dagger symbol (†)

Example:

Cognitive Support Blend            1,000 mg  †
  Bacopa Monnieri Leaf Extract
  Lion's Mane Mushroom (Hericium erinaceus)
  Ginkgo Biloba Leaf Extract
  Phosphatidylserine

† Daily Value not established

Pro Tip

While proprietary blends are legal, they're increasingly controversial. Informed consumers prefer full transparency. Consider whether the competitive protection of a proprietary blend is worth the potential trust trade-off with your target audience.

Step 4: Calculate and Display Daily Value Percentages

Daily Values (DVs) are reference amounts established by the FDA for vitamins and minerals. They represent the amount needed by an average adult consuming 2,000 calories per day.

How to Calculate % DV

Formula: (Amount per serving ÷ Daily Value) × 100 = % DV

Example: Your product contains 90 mg of Vitamin C per serving. The DV for Vitamin C is 90 mg.

Calculation: (90 mg ÷ 90 mg) × 100 = 100% DV

Key Daily Values to Know

Here are the most common DVs you'll use:

• Vitamin A: 900 mcg RAE
• Vitamin C: 90 mg
• Vitamin D: 20 mcg (800 IU)
• Vitamin E: 15 mg
• Vitamin K: 120 mcg
• Thiamin: 1.2 mg
• Riboflavin: 1.3 mg
• Niacin: 16 mg NE
• Vitamin B6: 1.7 mg
• Folate: 400 mcg DFE
• Vitamin B12: 2.4 mcg
• Biotin: 30 mcg
• Pantothenic Acid: 5 mg
• Calcium: 1,300 mg
• Iron: 18 mg
• Magnesium: 420 mg
• Zinc: 11 mg

For the complete list, reference 21 CFR 101.9(c)(8)(iv).

When to Use "†" Instead of % DV

Use the dagger symbol (†) and the footnote "Daily Value not established" when:

• No DV exists for the ingredient
• The ingredient is part of a proprietary blend
• The ingredient is a botanical, amino acid, or other non-vitamin/mineral dietary ingredient

Step 5: Format Your Panel According to FDA Specifications

The FDA has precise requirements for how your Supplement Facts panel must look.

Required Elements and Layout

Header:

• "Supplement Facts" in bold, larger type than other text
• Must be at least 2 points larger than the largest type used in the panel

Ruling Lines:

• Thick line (3 points) below "Supplement Facts"
• Thin line (0.5 points) below serving size information
• Thick line (6 points) above the footnote

Type Size:

• Minimum 6 point type for most information
• 8 point minimum for "Supplement Facts" heading
• Serving size may be up to 2 points smaller than other information

Alignment:

• Ingredient names: Left-aligned
• Amounts: Right-aligned in the amount column
• % DV: Right-aligned in the % DV column

Column Structure

Your panel must have clearly defined columns:

1. Ingredient column (left): Lists all ingredients
2. Amount column (center-right): Shows quantity per serving
3. % DV column (right): Displays percentage of Daily Value

Indentation Rules

• Main ingredients: No indentation
• Sub-ingredients or forms: Indent 2-3 spaces
• Proprietary blend components: Indent under blend name

Example:

Calcium (from Calcium Carbonate)   500 mg   38%
Magnesium                          200 mg   48%
  (as Magnesium Oxide, 
   Magnesium Citrate)

Pro Tip

Use professional label design software or work with a designer experienced in supplement labeling. Small formatting errors—wrong line weights, incorrect type sizes, improper alignment—can trigger compliance issues even if your content is accurate.

Step 6: Add Required Footnotes

Footnotes provide context and clarification for your Supplement Facts panel.

Mandatory Footnote

If any ingredients lack established Daily Values, you must include:

"† Daily Value not established"

This appears at the bottom of your panel, separated by a thick horizontal line (6 points).

Optional Reference Statement

You may include (but aren't required to include):

"Percent Daily Values are based on a 2,000 calorie diet."

This is more common on food products but can appear on supplements if you choose.

Other Ingredients Statement

If your product contains non-dietary ingredients (excipients, fillers, binders, etc.), list them below the Supplement Facts panel under "Other Ingredients:"

Example:

Other Ingredients: Microcrystalline Cellulose, 
Vegetable Magnesium Stearate, Silicon Dioxide, 
Hypromellose (Capsule)

List these in descending order by weight, just like on a food label.

Step 7: Review for Common Compliance Mistakes

Before finalizing your label, check for these frequent errors:

Mistake 1: Incorrect Units

Wrong: Using "g" for micrograms Right: Use "mcg" for micrograms, "mg" for milligrams, "g" for grams

Mistake 2: Missing Source Information

Wrong: "Vitamin E - 15 mg" Right: "Vitamin E (as d-alpha Tocopherol) - 15 mg"

Mistake 3: Improper Blend Formatting

Wrong: Listing blend ingredients with individual weights Right: Total blend weight only, with ingredients in descending order

Mistake 4: Outdated Daily Values

The FDA updated Daily Values in 2016 (effective 2020). Make sure you're using current values, not outdated RDIs.

Example: Vitamin D changed from 400 IU to 800 IU (20 mcg)

Mistake 5: Inconsistent Serving Size

Your serving size in the Supplement Facts panel must exactly match your directions for use on the main label.

Mistake 6: Missing Dagger Symbols

Every ingredient without an established Daily Value needs a dagger (†) in the % DV column.

Mistake 7: Type Size Too Small

Measure your actual printed label—not just the digital file. Type that looks legible on screen may be too small when printed.

Step 8: Work with Qualified Professionals

Creating a compliant Supplement Facts panel requires specialized knowledge. Before going to production:

Consult a Regulatory Expert

Work with a regulatory consultant who specializes in dietary supplements. They can:

• Review your complete label for compliance
• Verify your Daily Value calculations
• Check formatting against FDA requirements
• Identify potential claim issues
• Ensure consistency across your label elements

Engage a Licensed Professional

Depending on your product:

• Formulation chemist: Validates your formula and ingredient interactions
• Quality assurance specialist: Ensures your manufacturing process supports label claims
• Legal counsel: Reviews claims and marketing language for compliance

Verify with Your Manufacturer

Reputable contract manufacturers will review your label as part of their quality systems. They can catch errors and suggest improvements based on their experience.

Many manufacturers won't proceed with production until they've approved your label—this protects both parties.

Platform Tools for Label Creation

Modern product development platforms like Genie can streamline the label creation process by:

• Maintaining current Daily Value databases
• Automatically calculating % DV based on your formula
• Generating properly formatted Supplement Facts panels
• Flagging common compliance errors
• Creating production-ready specifications

These tools don't replace regulatory review, but they reduce manual errors and accelerate the development timeline.

Understanding Label Compliance Beyond the Supplement Facts Panel

While the Supplement Facts panel is the most technical element, it's just one part of a compliant supplement label. Your complete label must also include:

Required Elements

1. Product identity statement: What the product is ("Multivitamin Supplement")
2. Net quantity of contents: How much product is in the container
3. Directions for use: How to take the product
4. Manufacturer information: Name and address of manufacturer or distributor
5. Ingredient list: All ingredients in descending order by weight (if not in Supplement Facts panel)

Prohibited Elements

Your label cannot:

• Make disease claims without FDA approval
• Use terms like "cure," "treat," or "prevent" related to diseases
• Include false or misleading information
• Suggest FDA approval or endorsement
• Make structure/function claims without a disclaimer

Structure/Function Claims

If you make claims about how your supplement supports normal body functions ("supports immune health," "promotes joint comfort"), you must include:

"This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease."

This disclaimer is required even though it's not part of the Supplement Facts panel itself.

Testing and Verification Requirements

Before printing your final labels, ensure your product matches what you're declaring:

Identity Testing

Verify that the ingredients in your formula match what's listed on your label. This typically involves:

• Certificate of Analysis (COA) from raw material suppliers
• Identity testing using methods like HPLC, TLC, or FTIR
• Verification that botanical ingredients are the correct species

Potency Testing

Confirm that your product contains the amounts declared on the label:

• Test finished product samples
• Verify active ingredient levels
• Account for overage (extra amount added to ensure label claim throughout shelf life)
• Test at multiple time points to establish stability

Contaminant Testing

Depending on your ingredients and target market:

• Heavy metals (lead, arsenic, cadmium, mercury)
• Microbial contaminants
• Pesticide residues
• Allergen testing if making allergen claims

Proper testing ensures your label is truthful and not misleading—a core requirement of FDA regulations.

Frequently Asked Questions

Can I use IU instead of mcg for vitamins?

The FDA now requires vitamins to be declared in metric units (mcg or mg) rather than International Units (IU). You may include IU in parentheses for consumer familiarity, but the primary declaration must be in metric units. For example: "Vitamin D 20 mcg (800 IU)" is acceptable, but "Vitamin D 800 IU" alone is not compliant.

Do I need to list inactive ingredients in the Supplement Facts panel?

No. Inactive ingredients like fillers, binders, and capsule materials should be listed separately under "Other Ingredients" below the Supplement Facts panel. Only dietary ingredients—those that provide nutritional or therapeutic value—appear within the panel itself.

What's the difference between a proprietary blend and a regular ingredient list?

A proprietary blend allows you to group multiple ingredients under one total weight without disclosing individual amounts, protecting your formula. Regular listings require specific amounts for each ingredient. You can only use proprietary blends for ingredients without established Daily Values, and you must still list all ingredients in the blend in descending order by weight.

How do I handle ingredients with multiple forms or sources?

List all forms in parentheses after the ingredient name, separated by commas. For example: "Magnesium (as Magnesium Oxide, Magnesium Citrate) 200 mg 48%". If the amounts from each source differ significantly, you may list them as separate line items with their individual amounts and sources.

Can I round percentages of Daily Value?

Yes, the FDA allows rounding for % DV declarations. Round to the nearest whole number (5% increments for amounts less than 10%, whole percentages for 10% and above). However, you must round consistently throughout your panel. Never round in a way that's misleading—if your product contains 99.5% of the DV, you can round to 100%, but if it contains 94%, you should not.

What if my product is intended for children—do I use different Daily Values?

Yes. If your supplement is specifically formulated and marketed for children under 4 years of age, or for children 4 years and older, you must use the appropriate Daily Values for those age groups, which differ from adult values. The FDA provides separate DV tables for these populations in 21 CFR 101.9. Your label should clearly indicate the intended age group.

Key Takeaways

Creating a compliant Supplement Facts panel requires attention to detail and understanding of FDA regulations:

1. Serving size must match your directions for use and reflect realistic consumption patterns
2. Ingredient order matters: mandatory nutrients first, then vitamins/minerals, then other dietary ingredients
3. Source information is required for all vitamins, minerals, and botanical ingredients
4. Daily Value calculations must use current FDA values, not outdated reference amounts
5. Formatting specifications are precise: line weights, type sizes, and alignment are all regulated
6. Proprietary blends have specific rules and can only include ingredients without established DVs
7. Professional review is essential: work with regulatory consultants and your manufacturer
8. Testing validates your label claims: ensure your product matches what you declare

Your Supplement Facts panel is more than a regulatory requirement—it's a trust signal to consumers and healthcare providers. Invest the time to get it right.

Ready to streamline your supplement development process? Genie's product development platform includes tools for formula documentation, COGS modeling, and production specifications—helping you move from concept to compliant product faster. Get started free on Genie.