Sort the front
Claims, badges, moods. Three piles. Most fronts are mostly pile three.
How To Read A Supplement Claim
Written by the Memoahoney Editorial Desk · Reviewed by Dr. Judith Leone-Friedman, neuropsychologist · Revised
Ten minutes that will change how every bottle in the aisle reads.
Quick answer
A dietary supplement may make a structure and function claim — a statement that an ingredient affects the normal structure or function of the body, such as supports healthy blood glucose levels. It may not make a disease claim, which 21 CFR 101.93(g)(1) defines broadly as damage to an organ, part, structure or system such that it does not function properly. Structure and function claims must carry the FDA disclaimer, usually marked with an asterisk. The disclaimer is a required footnote to permitted claims; it does not make an impermissible claim acceptable.
There are only two kinds of claim that matter
The first is a structure and function claim. It says an ingredient affects the normal structure or function of the body. Supports healthy blood glucose levels. Supports immune function. Supports digestive comfort. These are permitted, and they must carry the FDA disclaimer.
The second is a disease claim. It says the product diagnoses, treats, cures, mitigates or prevents a disease. That territory belongs to drugs, which go through an approval process a supplement does not.
Everything else on a pack — badges, seals, adjectives, three-word taglines — is marketing that sits outside both categories, and most of it carries no defined meaning at all.
Once you can sort a front panel into those three piles, most supplement packaging becomes quite easy to read.
How broadly disease is defined
21 CFR 101.93(g)(1) defines a disease as “damage to an organ, part, structure, or system of the body such that it does not function properly … or a state of health leading to such dysfunctioning”.
That is much broader than most people expect. It captures named conditions, but it also captures states of health that lead to them.
Paragraph (g)(2) then lists the ways a claim can be made. The first factor is the name of the product. Others include statements about the formulation, citations to publications, and pictures or symbols on the label.
This is the part people miss most often. A claim does not have to be a sentence. A product name, a picture, or a phrase printed under a wordmark can all count.
Why the name matters
Because a name travels with the product everywhere: on the shelf, in an advert, in a search result, in a conversation. The regulation treats it as a claim for exactly that reason.
What the asterisk is actually for
An asterisk is a reference mark. Its job is to connect a claim to the footnote that qualifies it.
On a supplement pack, the convention is that each structure and function claim carries an asterisk, and the FDA disclaimer answers it: These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure or prevent any disease.
So when you pick up a bottle, look at the claims first and ask whether each one is marked. Then find the disclaimer and check that it is on the same label and reasonably placed.
A missing asterisk is rarely the most serious thing on a pack. It is a useful tell about how carefully the pack was produced — and production care is correlated with other kinds of care.
What the disclaimer is, and what it is not
It is a required footnote attached to permitted structure and function claims. It tells the reader that the FDA has not evaluated the statement.
It is not a licence. Printing it does not make a disease claim permissible, any more than a warning label makes an unsafe product safe. A disclaimer qualifies claims that were allowed to begin with.
It is also not a sign that anything is wrong. Almost every supplement in the market carries it, because almost every supplement makes some structure and function claim.
The practical use of the disclaimer, for a reader, is that its presence tells you the product is being sold as a supplement rather than a drug, and that nobody has reviewed the claims on the front.
Sorting real phrases into the three piles
| Phrase | Which pile | Why |
|---|---|---|
| Supports healthy blood glucose levels | Structure and function | Describes an effect on a normal body function, with no disease named |
| Improves insulin sensitivity | Structure and function, at the edge | “Improves” is stronger than “supports”, and insulin sensitivity is a clinical measure |
| Blood Sugar Support | Structure and function | Describes an effect on a normal body process, with no disease named |
| Made in an FDA-registered facility | Marketing, accurate | A registration. Not an approval, not an inspection result |
| FDA approved | Never accurate | FDA does not approve dietary supplements before marketing |
| Doctor formulated | Marketing | Means nothing unless a doctor is named and checkable |
| Natural ingredients | Marketing | No regulatory definition for a dietary supplement |
| Science · Health · Trust | Marketing | Three words with no referent |
Then turn the bottle round
The front of a pack is written by marketing. The Supplement Facts panel is written by regulation. That is why the back is worth more of your attention than the front.
Count the ingredients with a printed amount, then count the ones inside a proprietary blend. A blend declares only its total weight and lists its contents in descending order by weight, under 21 CFR 101.36(c). Individual amounts are not required.
Descending order still gives you something: the ingredient in position n cannot exceed the total divided by n. That is the only arithmetic a blend permits, and it produces ceilings rather than amounts.
Then look for standardisation percentages on anything described as an extract. Without one, even a printed milligram figure cannot be matched to a trial — and inside a blend, where there is no milligram figure at all, a percentage applied to a ceiling is the only number available.
A three-step habit
Count the back
Amounts printed versus amounts hidden. Write the ratio down; it is the single most useful number about any supplement.
Read the cautions
The one paragraph on the pack written by somebody worried about being wrong. It usually contains the most specific information on the label.
About this guide
It is a general explainer about how supplement claims are regulated, written for readers rather than lawyers. It is not legal advice and it is not medical advice, and it makes no claim about any particular product. The regulations quoted are linked in full in our source list.
How To Read A Supplement Claim: common questions
Is it FDA approved?
No dietary supplement is. The FDA “does not have the authority to approve dietary supplements before they are marketed”. The listing's badge says a registered facility, which is an administrative filing about a factory rather than an assessment of the product.
Are the claims allowed?
The bottle's claim is ordinary structure-function wording and names no disease. The listing's five reach further — protect the brain from oxidative stress and improve mental clarity use verbs of prevention and outcome — but still name no disease. Our claims page takes each one separately.
Does it protect the brain from oxidative stress?
Nothing in the seven printed ingredients is an antioxidant in the ordinary sense, and none of the sources we opened attaches an oxidative-stress effect to arginine, citrulline or beta-alanine at any dose. It is the claim in this pack we would drop first.
The artwork says six ingredients. The panel says seven.
It does. The Inside MemoHoney artwork is headed six named ingredients and the written brief lists the same six; both omit the calcium, which is on the panel at 18 mg. Nothing is concealed, because the panel is the document that governs and it lists all seven. But a buyer reading only the artwork has seen six of the seven.
Who makes it?
The manufacturer is not named. The label prints Distributed by: Instituto Experience, PO Box 12730, Ogden, UT 84404, with a telephone number and an email. 21 CFR 101.5 requires the name and place of business of the manufacturer, packer or distributor, and permits a street address to be omitted only if it is shown in a current city or telephone directory. We could not verify that either way.
What is the lot number?
MEM-26/ME-7647, with the certificate reference MEM-7647-26-ME. The pack's own note says these are draft labels rather than lab proof, and we publish them on that basis.
Ready to try MemoHoney?
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.
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