Updated 2026-10-01. This page is not legal advice.
Supplement Facts vs Nutrition Facts panels look alike at first glance. A conventional food uses a Nutrition Facts panel under 21 CFR 101.9. A dietary supplement uses a Supplement Facts panel under 21 CFR 101.36. The two panels look alike. The federal rules under them differ in fundamental ways. You must choose the right panel before you print your product packaging. This guide puts both panels side by side. It explains the legal differences clearly.
Supplement Facts vs Nutrition Facts at a glance
The table below compares the basic rules for each panel side by side.
| Rule | Nutrition Facts (food) | Supplement Facts (dietary supplement) |
|---|---|---|
| Rule in the CFR | 21 CFR 101.9 | 21 CFR 101.36 |
| Panel title | “Nutrition Facts” | “Supplement Facts” |
| What sets the serving size | Reference amounts customarily consumed (RACC) | Recommended consumption amount on the label |
| Serving unit | Household measures like cups, tablespoons, or grams | Form units like tablets, capsules, packets, or drops |
| Nutrients at zero | Must declare core nutrients even when zero | Omitted when present at zero |
| Ingredients with no Daily Value | Not allowed inside the panel | Allowed inside the panel with a footnote symbol |
| Source ingredients and plant part | Listed only in the separate ingredient list | Allowed inside the panel in parentheses |
| Proprietary blend | Not allowed | Allowed under a specific blend heading |
| Ingredient list heading | “Ingredients:” | “Ingredients:” or “Other ingredients:” |
| “Amount Per Serving” heading | “Amount Per Serving” or “Amount per serving” | “Amount Per Serving”, or units like “Amount Per Tablet” |
The 15 core nutrients are the same list on both panels. These nutrients include total calories, total fat, saturated fat, trans fat, and cholesterol. They also include sodium, total carbohydrate, dietary fiber, total sugars, added sugars, and protein. Finally, they include vitamin D, calcium, iron, and potassium.
Which products need a Supplement Facts label?
The primary classification of your product determines which panel you must use. Under 21 CFR 101.3(g), “Dietary supplements shall be identified by the term “dietary supplement” as a part of the statement of identity”. The statement of identity is the legal name of the product on the front label. A maker may replace the word “dietary” with an ingredient name. Examples include “calcium supplement” or “herbal supplement with vitamins”. A product labeled as a supplement must use a supplement facts label.
Tablets, capsules, softgels, powders, and liquids sold as supplements use Supplement Facts. Conventional foods and drinks sold for ordinary nourishment use a nutrition facts label. One product carries one panel, never both. A product cannot be a conventional food and a dietary supplement at the same time.
How the label names and represents the product decides which panel applies. The table below shows common examples.
| Sold as | Panel |
|---|---|
| Vitamin gummies sold as a dietary supplement | Supplement Facts |
| Protein powder labeled “dietary supplement” | Supplement Facts |
| Protein powder sold as a food, such as a shake mix | Nutrition Facts |
| Granola or a baked good | Nutrition Facts |
| A herbal capsule | Supplement Facts |
A maker cannot choose a panel at random. A dietary supplement label must follow supplement rules from the front panel to the back panel. If you sell your product as food, it must carry a Nutrition Facts panel.
How does the serving size differ?
Serving sizes follow two very different standards. For conventional food, the serving size comes from FDA reference amounts customarily consumed in 21 CFR 101.12(b). The RACC is the standard amount of food that people normally eat in one sitting. Federal tables set these amounts for each food category. A food maker must calculate its household measure from that federal reference amount.
A dietary supplement does not use the RACC tables to set its serving size. Instead, 21 CFR 101.12(b), Table 2, states the rule for dietary supplements: “The maximum amount recommended, as appropriate, on the label for consumption per eating occasion or, in the absence of recommendations, 1 unit, e.g., tablet, capsule, packet, teaspoonful, etc”
The label directions determine the serving size for a supplement. If the directions say to take two capsules with breakfast, the serving size is two capsules. If the label gives no directions, the serving size defaults to one single unit. Common units include tablets, capsules, packets, and teaspoonfuls.
Why does a Supplement Facts panel skip zero amounts?
The handling of zero amounts shows a clear difference between supplement facts and nutrition facts. A Nutrition Facts panel must declare all 15 core nutrients. It must declare them even when the amount present rounds down to zero. For example, a food label must print “Trans Fat 0g” and “Cholesterol 0mg”. A food panel cannot hide these zero lines.
A Supplement Facts panel works under the opposite rule. Under 21 CFR 101.36(b)(2)(i): “Any (b)(2)-dietary ingredients that are not present, or that are present in amounts that can be declared as zero in § 101.9(c), shall not be declared (e.g., amounts corresponding to less than 2 percent of the RDI for vitamins and minerals).”
A supplement maker must leave off any core nutrient that rounds to zero. You do not list zero fat, zero carbs, or zero sodium on a supplement panel. Because of this rule, a simple vitamin C tablet panel can show only one nutrient line. The panel stays compact and lists only what the supplement actually provides.
What can a Supplement Facts panel list that Nutrition Facts cannot?
A Supplement Facts panel can include items that are illegal inside a food panel. First, a supplement panel can list dietary ingredients that have no established Daily Value. Examples include botanicals, herbs, bioflavonoids, and amino acids. These items appear below the vitamins and minerals. Each item without a Daily Value receives a symbol, such as an asterisk. The symbol points to a required footnote at the bottom: “Daily Value not established.” When %DV is based on adults, the panel uses the standard footnote: “Percent Daily Values are based on a 2,000 calorie diet.” A Nutrition Facts panel cannot list these non-established ingredients inside the box.
Second, a supplement panel can state the source of an ingredient directly inside the box. The maker places the source in parentheses after the nutrient name. The source begins with the word “as” or “from”. The federal rule in 21 CFR 101.36(d) provides this exact example: “Calcium (as calcium carbonate),”. When a supplement contains a botanical ingredient, the panel must state the plant part. Examples include “root”, “leaf”, or “aerial parts”.
Third, a supplement panel can declare a proprietary blend. A proprietary blend is a custom mixture of dietary ingredients. The panel shows the blend name, such as “Proprietary Blend” or another descriptive name. The total weight of the entire blend appears on that same line. The maker then lists the individual ingredients indented below the blend name. These ingredients appear in descending order of predominance by weight. The exact weight of each individual ingredient in the blend stays private. A food panel cannot use proprietary blends.
Where does the ingredient list go?
The placement and title of the ingredient list differ between the two formats. On a conventional food package, the ingredient list is its own independent statement. It sits near the Nutrition Facts panel or on the information panel. It always starts with the word “Ingredients:”.
On a dietary supplement, 21 CFR 101.4(g) controls the placement. The ingredient list must sit immediately below the Supplement Facts panel. If space is too tight, it may sit immediately to the right of the panel. The heading depends on how the maker writes the panel. If all ingredient sources are listed inside the panel, the list uses the heading “Other ingredients:”. Those other ingredients include binders, flow agents, and capsule shells. If sources are not listed inside the panel, the heading simply reads “Ingredients:”. You can check all layout rules in our guide to supplement label requirements.
What about claims and the FDA disclaimer?
Dietary supplement labels often carry structure or function claims. These claims describe how a nutrient supports a bodily function. Whenever a supplement label makes this claim, it must display a mandatory disclaimer. The disclaimer comes from 21 CFR 101.93(c)(1): “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.”
This text must appear inside a box on the label. It must link to the claim with a matching symbol. The FDA does not approve dietary supplements or their labels before commercial sale. The agency takes action after sale through warning letters and recalls. Conventional foods do not use this disclaimer box. Foods follow distinct claim standards explained in our guide to food label requirements.
How do you make each label?
You can generate both panel types quickly with dedicated online software. Use the Nutrition Facts label maker to build a compliant panel for any conventional food. Use the Supplement Facts label generator if you manufacture or package a dietary supplement. Both tools are completely free and let you print high-resolution labels at home. Read our guide on the percent daily value to understand how %DV calculations work on both panels.