Health claims: the four sentences you are allowed to write

Most supplement marketing copy in Europe would not survive a claims review. Not because the products are bad, but because the copy was written first and checked afterwards — and the EU Claims Regulation does not work that way.

The regulation operates on a closed list. A nutrition or health claim may be used only if it is authorised, and it is authorised for a substance at a minimum dose, not for a product and never for a brand.

The four things a claim can actually say

Strip away the marketing and almost every compliant claim on a European supplement pack is one of four types:

1. A nutrition claim — a statement about what the product contains, from a fixed list: “source of”, “high in”, “low in”, and their defined equivalents. These have numeric thresholds attached and nothing else.
2. An authorised function claim — a nutrient’s role in the body, in the authorised wording or a close variant with the same meaning. “Zinc contributes to normal fertility and reproduction” is authorised; “zinc boosts fertility” is not the same claim.
3. A reduction-of-disease-risk claim — a small, specifically authorised set, each with mandatory accompanying wording.
4. A children’s development claim — likewise a short authorised list.

Everything outside those four is either a medicinal claim, which requires an authorisation, or an unauthorised claim, which is simply prohibited.

The dose gate

An authorised claim may only be used if the product supplies a significant amount of the nutrient the claim belongs to — generally 15% of the nutrient reference value per portion, with higher thresholds for “high in” claims.

This is the single most useful compliance test available, and it takes a spreadsheet. Take every claim you want to make, map it to the nutrient that carries it, and check the dose per daily portion. Claims that fail the gate come off the pack. There is no argument to be had.

It is also why claim-driven formulation exists: if a claim matters commercially, the dose has to be designed to carry it, not discovered afterwards.

Botanicals: the uncomfortable part

Health claims for botanical substances have largely been left on hold in the EU. In practice this means that the ingredient your product is built around — the extract in the name, the one the consumer is buying — usually carries no authorised claim at all.

The compliant answer is not to imply the claim more carefully. It is to let the vitamins and minerals carry the permitted messaging while the botanical is described factually: what it is, how much is present, where it comes from. Our own EMASEX® Libo+ and Zellaforte® KeraBiotic pages are written on exactly that division, and it is a fair illustration of how much room the framework really leaves.

Implied claims count

Authorities and courts assess the impression created, not only the sentences written. That includes:

• Imagery — a visual suggesting a therapeutic effect is a claim.
• Product and range names — a name that states an effect is a claim, and grandfathering is narrower than most brands assume.
• Testimonials and creator content — a claim made by an influencer on your behalf is your claim.
• Retailer and marketplace listings — including copy a retailer wrote, if you supplied the material behind it.
• Adjacency — a compliant pack next to a non-compliant landing page is assessed together.

A practical order of work

Write the claim framework before the copy. Concretely:

1. List every nutrient in the formula with its dose per daily portion.
2. Pull the authorised claims for each nutrient that clears the significance threshold.
3. Write that list down as the permitted vocabulary — and a second list of prohibited terms.
4. Give both lists to everyone who writes anything: agency, retailers, affiliates, creators.
5. Review the whole commercial context against the lists, not just the pack.

Copywriting inside a fixed vocabulary is harder and slower. It is also the only version of this work that does not have to be redone.

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A claim audit of existing pack and web copy is one of the most common first engagements we run, and usually the cheapest risk reduction available — see regulatory coordination.