Supplement Facts vs Nutrition Facts: Which Label Does Your Product Need?

FDA COMPLIANCE · DIETARY SUPPLEMENT LABELS

Updated November 2026. Supplement brands moving into powders, gummies, shots and drink mixes often ask which label goes on the back. The answer decides more than the title of a box. It changes which ingredients you can show, how you set the serving size, and whether the product is regulated as a supplement or as a food. This guide compares the two panels and lists the mistakes that most often trigger label rework, marketplace holds or FDA letters. It is general information, not legal advice.

What is the difference between Supplement Facts and Nutrition Facts?

FDA’s Dietary Supplement Labeling Guide lists five main differences:

1. Ingredients without Daily Values. Supplement Facts must list dietary ingredients that have no Reference Daily Intake or Daily Reference Value, such as ashwagandha or creatine. Nutrition Facts may not list them.
2. Source of an ingredient. Supplement Facts may name the source, such as “Calcium (as calcium carbonate).” Nutrition Facts may not. When the source appears in the panel, it does not have to be repeated in the ingredient list.
3. Plant part. Supplement Facts must name the part of the plant a botanical comes from, such as root or leaf. Nutrition Facts cannot.
4. Zero amounts. Supplement Facts may not list nutrients present at zero. Nutrition Facts must list required nutrients even when the amount is zero.
5. Title. The panel for a supplement is titled “Supplement Facts,” never “Nutrition Facts.”

Both panels were revised by FDA’s 2016 final rule, “Revision of the Nutrition and Supplement Facts Labels,” which updated Daily Values and the list of required nutrients. Labels designed before that rule, or copied from an old template, are a common source of errors.

How do you know if your product is a dietary supplement or a food?

Under the FD&C Act, a dietary supplement is intended to supplement the diet and is not represented for use as a conventional food or as a sole item of a meal or the diet. Calling a product a supplement does not make it one. FDA’s 2014 guidance on distinguishing liquid dietary supplements from beverages says FDA looks at the whole picture:

• Name and packaging. Terms like “beverage,” “drink,” “water” or “soda,” or packaging that looks like a soft drink, point to a conventional food.
• Serving size and daily intake. A recommended intake in the volume people drink as a beverage points to food.
• Directions for use. “Take one tablespoon three times a day” fits a supplement. “Refreshing” or “quenches thirst” fits a beverage.
• Marketing. Comparing a product to sodas, placing it in the beverage aisle, or using search tags for juices can represent it as a food.

The same logic applies to bars, chews and powders. A protein powder marketed as a meal replacement will usually need Nutrition Facts. A capsule or tablet sold to supplement the diet uses Supplement Facts. For a supplement, the statement of identity on the front must also include the term “dietary supplement,” or a version that replaces “dietary” with the ingredient name, such as “Vitamin C Supplement” (21 CFR 101.3(g)).

What must appear in a Supplement Facts panel?

• Serving Size, using that exact term. For a supplement, one serving is the maximum amount recommended on the label per eating occasion, or one unit if there is no recommendation. If the label says “take 1 to 3 tablets,” the serving size is 3 tablets.
• Servings Per Container, unless it repeats the net quantity statement.
• Dietary ingredients with Daily Values, in FDA’s set order, with the amount per serving and the % Daily Value. Required nutrients appear only when present in measurable amounts.
• Other dietary ingredients without Daily Values, listed after them by common name with the weight per serving and a symbol leading to the footnote “Daily Value not established.”
• Proprietary blends, identified as such, with the total weight of the blend and its ingredients listed in descending order by weight.

Binders, fillers, coatings and other non-dietary ingredients go in an “Other ingredients” list below the panel. Allergen disclosure still applies; see our food labeling and allergen guide.

How does the Nutrition Facts panel work for foods?

The Nutrition Facts panel uses serving sizes based on how much people actually eat, set by FDA reference amounts, not the maker’s directions. It must show calories in large bold type, the full list of required nutrients even at zero, “Includes X g Added Sugars,” and the amount and % Daily Value for vitamin D, calcium, iron and potassium. It ends with FDA’s standard % Daily Value footnote. Packages that hold one to two servings are labeled as one serving, and some larger packages need dual columns. Most manufacturers had to use the updated format by January 1, 2020 or January 1, 2021, depending on annual food sales.

What label mistakes cause the most problems?

• Wrong panel for the category. A “supplement” sold as a drink, or a food listing botanicals in Nutrition Facts.
• Zeros in Supplement Facts. Lines such as “Total Fat 0 g” do not belong in a supplement panel.
• Salt weight instead of nutrient weight. FDA’s guide says to list the weight of the calcium, not the calcium carbonate.
• Missing plant part. “Turmeric 500 mg” needs the part, such as “Turmeric (root).”
• Amounts that do not match the product. FDA’s guide says added dietary ingredients must be present at 100% of the declared amount, and naturally occurring ones at least 80%.
• Claims mixed into the panel. Claims need their own placement and, for structure/function claims, FDA’s disclaimer. See our structure/function claims guide.

Marketplaces review label images too. A panel that does not match the listing, or a claim that crosses into disease treatment, can stop a launch. Our article on FDA warning letters for online sellers shows how label issues escalate.

Does a supplement need FDA registration as well as a label?

Usually, yes, but not for the label. Facilities that manufacture, process, pack or hold supplements for U.S. consumption generally register as food facilities and renew between October 1 and December 31 of every even-numbered year, so 2026 is a renewal year. See our 2026 food facility renewal guide. Registration does not mean FDA approval, and neither does a compliant label. Our answer on handling FDA registration and an Amazon launch with one partner covers the full sequence.

How Eva Commerce helps

Eva Commerce reviews supplement and food labels against FDA rules, from panel type and serving size to ingredient order, plant parts, other ingredients and claims, and files the facility registration, U.S. Agent service ($250 a year) and Prior Notice your product needs. Published prices for label review and every other FDA service are on our FDA compliance services page.

Because Eva also runs Amazon, Walmart, TikTok Shop and Shopify growth for supplement brands, the label, the listing images and the ad copy stay consistent. Book a call or call 858-315-2020 to have your panel checked before your next print run.

Frequently asked questions

What is the difference between Supplement Facts and Nutrition Facts?

Supplement Facts is the panel for dietary supplements and Nutrition Facts is for conventional foods. Supplement Facts must list ingredients without Daily Values and plant parts, may show nutrient sources, and may not list zero amounts. Nutrition Facts must list required nutrients even at zero.

Can a gummy or a drink use a Supplement Facts label?

Yes, if it is truly a dietary supplement. FDA looks at the name, packaging, serving size, directions and marketing. A product marketed as a beverage or snack is a conventional food and needs Nutrition Facts.

How is serving size set on a Supplement Facts panel?

It is the maximum amount the label recommends per eating occasion, or one unit if there is no recommendation. If the directions say 1 to 3 capsules, the serving size is 3 capsules.

Where do fillers and capsule ingredients go?

Non-dietary ingredients such as binders, fillers, coatings and capsule shells go in the “Other ingredients” list below the Supplement Facts panel, not inside it.

Does FDA approve Supplement Facts labels?

No. FDA does not review or approve supplement labels or products before they are sold. The brand is responsible for a truthful, compliant label, and FDA can act after a product is on the market.

Can Eva Commerce review my supplement label?

Yes. Eva reviews Supplement Facts and Nutrition Facts panels, claims and ingredient lists, and handles FDA registration for supplement brands. Book a call or call 858-315-2020.

Sources: FDA, Dietary Supplement Labeling Guide: Chapter IV. Nutrition Labeling; FDA, Dietary Supplement Labeling Guide; FDA, Changes to the Nutrition Facts Label; FDA, Guidance for Industry: Distinguishing Liquid Dietary Supplements from Beverages (January 2014); FDA, Dietary Supplements; 21 CFR 101.3(g), 101.9 and 101.36. General information, not legal advice.

Related Eva guides: FDA compliance services, structure/function claims guide, food labeling and allergen guide, FDA registration and U.S. Agent guide, how to start a supplement brand.