By Curtis Walcker, M.S.
July 20, 2021
If you are a frequent reviewer of dietary supplement labels, you have probably found that your speed and efficiency increase when you have your “tools” readily accessible. All the way back in 2014, we published the Part 1 to this article, and are finally making good on the Part 2. The previously named tools included 1) the regulations and guidance documents, 2) a calculator for percent Daily Values, and 3) the FDA Warning Letters published weekly. Here are three additional tools to use and where to get them.
Tool #4 – Herbs of Commerce
It is pretty tough to properly label botanical ingredients without this critical reference tool. In fact, 21 CFR 101.4(h) actually requires that the common or usual names of dietary ingredients that are botanicals (including fungi and algae) be consistent with the names standardized in Herbs of Commerce. It can be purchased through the American Herbal Products Association’s website here. You will be amazed to find how many “common” names used for botanicals are not technically appropriate for labeling.
Tool #5 – FDA’s high-resolution Supplement Facts panel examples
We share the link to this tool with clients and designers maybe more than anything else. And while you must have some knowledge of required formatting and when and where to use certain formats, the FDA’s High-Resolution Examples of Different Supplement Facts Labels in the New Format is invaluable for quickly viewing a range of Supplement Facts panel types. This is a far safer model for your own labels than competitor labels!
Tool #6 – A (NEW!!) % Daily Value calculator
Although this is the same tool we recommended in the Part 1 of this article, enough time has passed that the labeling regulations have been changed, and with them came many new Daily Values and even units of measure. So once again, if you are currently using a regular calculator for determining your declarations, you are wasting far too much time. Using a program such as Microsoft Excel, you can create your own spreadsheet, where you can enter in the label values for nutrients and it will give you the percentages. A proper and efficient one will be built so that all of the nutrients are already in the order that they must be declared on the label, the correct nomenclature is used, the defined units of measure are used, and the numbers are automatically rounded to the nearest whole percentages. Not up to building one or just need a better one? Our newest version can be downloaded for a small fee here.