Build an fda-compliant supplement facts panel for your supplement

Build My Label

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The problem, in your words

Your contract manufacturer sent a spec sheet. Your designer sent back a panel that looks right, and you can't tell whether it is right, because every labeling article you've read is about cookies and hot sauce. The trap is that a Supplement Facts panel looks like a Nutrition Facts panel, so generic label tools will happily build you one. Then the differences bite.

Six ways Supplement Facts differs from Nutrition Facts

1. The header reads "Supplement Facts." Per 101.36(e)(1) it's set larger than all other print in the panel, and bolded. A panel headed "Nutrition Facts" on a supplement is wrong on line one.

2. Serving size comes from your label, not a RACC table. 101.36(b)(1)(i) routes through 21 CFR 101.12 Table 2 — and the Table 2 entry for dietary supplements is "the maximum amount recommended, as appropriate, on the label for consumption per eating occasion or, in the absence of recommendations, 1 unit." If your directions say take two capsules, your serving size is 2 capsules. You define it through your dosing instructions. There's no 30 g reference amount waiting to overrule you.

3. Ingredients with no Daily Value sit below a heavy bar. Under 101.36(b)(3)(iv), a dietary ingredient FDA hasn't set an RDI or DRV for carries a symbol in the % Daily Value column. That symbol points to a footnote placed, per 101.36(b)(2)(iii)(F), "below the last heavy bar and inside the box," reading "Daily Value not established." The regulation offers an asterisk as its example; the dagger (†) is the industry convention and is equally fine as long as the column symbol and the footnote symbol match. Your ashwagandha, your L-theanine, your CoQ10 — all daggered, all below the bar, all inside the box.

4. Proprietary blends declare a total, not a breakdown. 101.36(c) lets you list a blend under a descriptive name with one quantitative amount by weight for the whole blend and its components named underneath in descending order of predominance by weight, no individual amounts. What it doesn't let you do is bury a nutrient with an established Daily Value inside the blend. Those still get declared separately with their own amount and %DV.

5. "Other ingredients" go below the panel. Capsule shell, magnesium stearate, silica, rice flour. Under 21 CFR 101.4(g) the ingredient list sits immediately below the panel — or contiguous and to its right if there's no room — and ingredients outside the panel are preceded by the words "Other ingredients." Excipients inside the panel is one of the most common self-designed-label errors.

6. Botanicals must name the part of the plant. 101.4(h) and 101.36(d)(1) require it. "Turmeric" isn't enough. "Turmeric (Curcuma longa) root" is. Same for valerian root, echinacea aerial parts, ginkgo leaf. If it isn't in Herbs of Commerce, the Latin binomial comes along too.

No premarket approval, and nobody to check your work

Under DSHEA, dietary supplements are regulated as a category of food, not as drugs. There's no premarket approval. FDA doesn't review your formula before you sell it and FDA does not approve labels — anyone selling an "FDA-approved supplement label" is selling something that doesn't exist. The whole compliance burden lands on you, after launch, with no gate to pass and nobody to tell you it's right until someone tells you it's wrong.

The moment your label says "supports joint comfort," 21 CFR 101.93 attaches and you must carry this, verbatim:

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.

Plural if you make more than one claim. Per 101.93(d) and (e) it goes adjacent to the claim with no intervening material, boldface, type no smaller than one-sixteenth inch. Under 101.93(a)(1) you notify FDA within 30 days after first marketing. Go past structure/function into "lowers cholesterol" and you've made a disease claim, which makes your product an unapproved drug.

Amazon's December 2025 cGMP verification requirement

On December 19, 2025, Amazon announced that supplement sellers must supply verification from an Amazon-approved third-party Testing, Inspection and Certification body that the product was made in a cGMP-compliant facility. The rollout is phased; sellers who get contacted have 90 days to initiate the documentation request. Accepted programs reported include NSF/ANSI 455-2, USP GMP, Eurofins GMP, UL GMP, SGS, Intertek, SQF and GFSI-benchmarked schemes. Reported as not accepted: private audits, first-party audits, consulting audits, and FDA inspections of your contract manufacturer. That last one surprises everyone.

Amazon publishes this inside Seller Central behind a login, so these details come from trade press rather than a public Amazon page. Verify in your own account; the rest of the listing side is in our Amazon food label requirements guide.

What this costs you the other way

Supplement panels are the priciest line on a consultant's list because they're the fiddliest. But the number that actually decides this is revisions. Your manufacturer swaps a magnesium source. You bump vitamin D from 2,000 IU to 5,000. Legal wants the botanical genus added. Every one of those is a new consultant invoice and another $40 at an extension lab. Here it's a re-run: change the number, regenerate, download.

How it works

1. Get the formula in. Type it, paste the manufacturer's spec sheet, or photograph the COA and let us read it. Units convert automatically — mg, mcg, IU, mcg DFE, mg NE.
2. Mark what's what. DV-bearing vitamins and minerals, other dietary ingredients, blends and their components, other ingredients.
3. We build the panel to 101.36 layout spec: nutrient order, %DV against current RDI and DRV values, FDA rounding, heavy bars, the dagger and "Daily Value not established" footnote below the last bar and inside the box, botanicals with plant part, and the "Other ingredients" list positioned per 101.4(g). Structure/function disclaimer wording included if you're making those claims.
4. Download PNG, PDF and SVG at print resolution. 90 days of edits on the one-time; unlimited on any subscription.

The four questions everyone asks

"Is a calculated panel actually legal, or do I need lab testing?" Legal. FDA's position is that the source of the data used to calculate label values is the manufacturer's prerogative — you're responsible for the accuracy of the values, not for a particular route to them. For supplements the amounts come off your manufacturer's formulation sheet. You'd want lab data to verify potency or defend a borderline claim, not to produce the panel: do you have to send your food to a lab.

"Do I even need a panel?" If you're selling a dietary supplement, yes. 101.36 applies to the class, and the exemptions at 101.36(h) are narrow — the retailer carve-out tops out at $500,000 in annual gross sales and evaporates the moment your label carries a claim. No cottage-food route around this one. Other businesses, other answers: do I need a nutrition facts label.

"What if I get it wrong?" Rounding, %DV math against the correct RDI/DRV set, symbol-to-footnote matching, blend totals and ingredient-list placement are where self-built panels fail. The tool handles all five. See nutrition label rounding rules and why design-tool labels fail FDA spec.

"What if my formula changes?" You regenerate. Unlimited revisions on any subscription; 90 days of edits on the $39 one-time.

Social proof

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Pricing

Annual billing saves two months. One SKU and a stable formula: buy the $39. A line, or a manufacturer who changes things: the subscription pays for itself on the second revision.

Build the panel

Your formula in, a 21 CFR 101.36-compliant Supplement Facts panel out, in about a minute.

Build My Label