Find the total and count the names
Both are printed. The total is on the blend line and the names are underneath it. Write down how many there are.
Written by the Memoahoney Editorial Desk · Reviewed by Dr. Judith Leone-Friedman, neuropsychologist · Revised
One total, several names, no individual amounts — and one division that nobody tells you about.
A proprietary blend declares several dietary ingredients under a single total weight instead of individually. 21 CFR 101.36(c) permits this: the total weight of the blend must be declared and the ingredients in it must be listed in descending order of predominance by weight. No individual amounts are required. Because the list is ordered by weight, the ingredient in position n cannot exceed the blend total divided by n — so a blend still yields an upper bound for every ingredient in it, though never a lower one.
It is a line on a Supplement Facts panel that reads something like Proprietary Blend — 400 mg — †, followed by a list of ingredient names with no numbers beside any of them.
That is not a loophole somebody found. It is written into the regulation. 21 CFR 101.36(c) sets out how dietary ingredients that are not declared individually must be presented: the total weight of the blend is declared, and the ingredients inside it are listed in descending order of predominance by weight. Nothing further is required.
Ingredients without an established Daily Value carry a symbol — usually a dagger — pointing at the statement Daily Value not established. You will see that on almost every blend line in the aisle.
So when a company uses a blend, it is not hiding anything unlawfully. It is exercising an option the rules give it, and the question worth asking is what that option costs you.
The argument for. A formula is intellectual property. Publishing every amount lets a competitor copy the ratios exactly, and the ratios are frequently the only thing distinguishing one product from another in a category where the ingredients are all in the public domain. That is a real commercial concern and it is why the option exists.
The argument against. A blend also conceals how little of an expensive ingredient a formula contains. If a blend totals 400 mg and holds eight ingredients, one of them can be 393 mg of something cheap and the other seven a milligram each, and the label will be entirely truthful.
Both of those are true at the same time, on every blend, and the label never tells you which one applies. That is the actual problem: not that blends are dishonest, but that an honest blend and a cynical one look identical on the bottle.
There is a second cost, and it falls on people trying to be careful. A pharmacist checking an interaction needs an amount. A person comparing two products needs an amount. Somebody who has read the literature on a specific ingredient and wants a studied dose needs an amount. A blend removes the information from exactly the readers most likely to use it.
Proprietary blend, matrix, complex, formula, proprietary formulation. Any of them followed by a single weight and a list of names is the same thing under a different word.
It takes one division and it works on every blend on every shelf.
Descending order of predominance by weight is a formatting requirement, and it is also a mathematical constraint. Most people read it as the former. It is worth reading as the latter.
Here is the argument in full. Suppose a blend totals T milligrams and the ingredient in position n weighs more than T divided by n. Because the list is in descending order, every ingredient above it weighs at least as much. So those first n ingredients together weigh more than n times T/n, which is more than T — more than the whole blend. That is impossible.
Therefore: the ingredient in position n is at most T divided by n.
That single line is the entire method. The first ingredient can be the whole blend. The second can be at most half of it. The fifth at most a fifth. The tenth at most a tenth.
Then, if an ingredient carries a standardisation percentage, apply it. An extract that is eighteenth of twenty-two in a 200 mg blend is at most 11.1 mg, and if it is standardised to an active compound, that compound is at most 216 micrograms. A standardisation inside a blend is worth more than it looks, because it converts a ceiling on powder into a ceiling on something the research is written about.
A 400 mg blend with six ingredients. Position 1: at most 400 mg. Position 2: at most 200. Position 3: at most 133.3. Position 4: at most 100. Position 5: at most 80. Position 6: at most 66.7. If the ingredient you care about is fifth and the research used 300 mg, you already know the answer without any further information.
Total divided by position. Every figure is an upper bound, and none of them is a dose.
| Position in the list | In a 150 mg blend | In a 400 mg blend | In a 1,000 mg blend |
|---|---|---|---|
| 1st | ≤ 150 mg | ≤ 400 mg | ≤ 1,000 mg |
| 2nd | ≤ 75 mg | ≤ 200 mg | ≤ 500 mg |
| 3rd | ≤ 50 mg | ≤ 133 mg | ≤ 333 mg |
| 4th | ≤ 37.5 mg | ≤ 100 mg | ≤ 250 mg |
| 5th | ≤ 30 mg | ≤ 80 mg | ≤ 200 mg |
| 6th | ≤ 25 mg | ≤ 67 mg | ≤ 167 mg |
| 7th | ≤ 21.4 mg | ≤ 57 mg | ≤ 143 mg |
| 8th | ≤ 18.75 mg | ≤ 50 mg | ≤ 125 mg |
MemoHoney is a memory supplement in 30-capsule bottles, one capsule a day. Its panel declares seven ingredients and prints an amount for every one of them — and that disclosure is what lets anyone see how far below the studied doses those amounts sit. We publish the arithmetic rather than the adjectives.
Order NowRead the label firstIt produces no floor. There is no arrangement of the rules that puts a lower bound on any ingredient inside a blend. The fifth ingredient in a 400 mg blend is at most 80 mg, and it could be 0.1 mg, and the label would be equally accurate either way.
This is the part that gets lost when ceilings are quoted. A ceiling is the kindest possible reading of a label — the most generous number consistent with what is printed. When a review says an ingredient is at most 30 mg against a studied dose of 300, the honest gloss is that the gap is at least tenfold.
It cannot separate a good blend from a bad one. A company that puts studied doses of everything inside a blend produces exactly the same label as one that puts a dusting of everything but the cheapest ingredient. The method cannot distinguish them, and neither can you.
It cannot answer a safety question. A pharmacist can tell you whether 200 micrograms of an enzyme inhibitor is a concern alongside your prescription. Nobody can tell you whether somewhere between a trace and 216 micrograms is. Where a blend contains an ingredient with a documented interaction list, the ceiling is the beginning of a conversation rather than the end of one.
Both are printed. The total is on the blend line and the names are underneath it. Write down how many there are.
Find the ingredient you are buying the product for, count where it sits in the list, and divide the total by that number. That is the most it can be.
One source, opened and read. If the ceiling is far below what the study used, no amount of front-panel language changes the arithmetic.
Every argument on this page is about what a label permits. None of it stops a company answering a direct question.
If you are taking a prescription medicine and a blend contains an ingredient with a documented interaction, asking the seller for that one amount is a reasonable request with a clinical reason behind it. Some companies answer. Some publish a full panel on request. Some decline, which is itself information.
There is exactly one way to settle a dispute about a ceiling: print the amount. Any company that believes a review has understated what is in its product can end the argument in a single line of type, and the ones that do end it immediately.
It is a general explainer about a labelling rule, written for readers rather than lawyers, and it makes no claim about any particular product. It is not legal advice and it is not medical advice. The regulation quoted is linked in full in our source list, and the arithmetic on this page can be checked against it in about five minutes.
No, and it is the best thing about this label. Every dietary ingredient carries a printed amount. Nothing is concealed inside a total weight, nothing is described only as part of a matrix, and the panel can be added up by anyone with a calculator. Of the products this desk has reviewed, this is the first with a full house.
Because it is the difference between a review and a guess. When amounts are hidden, the most a site can honestly say is what an ingredient does in the literature and that nobody can tell how much is in the bottle. When they are printed, the comparison against the research becomes arithmetic, and arithmetic can be checked by the reader.
Per capsule: niacin 7.5 mg NE, calcium as calcium carbonate 18 mg, L-arginine base 200 mg, L-arginine AKG 2:1 extract 200 mg, L-citrulline HCl 100 mg, L-citrulline malate 100 mg and beta alanine 40 mg. Other ingredients: hypromellose vegetable capsule, vegetable stearate and silicon dioxide. The seven declared amounts come to 665.5 mg, which is our addition rather than the label's.
Fifteen capsules a day to reach 6 grams, which is the bottom of the range in the monograph we read. The label says one. The NIH is less encouraging still: it reports that 2 to 20 grams a day of arginine has little to no effect on performance, and little to no effect on nitric oxide concentration or blood flow.
Eighty capsules to reach the 8 gram citrulline malate protocol the NIH records. The label says one a day, so that is two and two-thirds bottles in a single day. It is the starkest comparison on the site.
The material does not say. Eighteen milligrams is 1.4% of the FDA's 1,300 mg Daily Value, which is not a calcium supplement by any definition. Calcium carbonate is also among the most common capsule fillers there is; we are not claiming that is what it is doing here, only that the amount is negligible as nutrition.
The label: as a dietary supplement, take one capsule daily with an 8 oz glass of water. For best results, take 20 to 30 minutes before a meal with 8 oz of water, or as directed by your healthcare professional.
One bottle is 30 capsules at one a day, so a bottle is thirty days and the 60-day guarantee still has thirty left to run when it ends. The guarantee runs from purchase, not from delivery, and the price is shown at checkout.
Order NowRead the label firstNo price was published to us. We print no figure we have not seen ourselves. · 60-day guarantee from purchase · Not for under 18, pregnancy or nursing