The two panels look similar but serve completely different regulatory purposes. Using the wrong one is a common FDA violation.
Nutrition Facts is for conventional foods (21 CFR 101.9). Supplement Facts is for dietary supplements (21 CFR 101.36). You cannot use a Nutrition Facts panel on a dietary supplement, and you cannot use a Supplement Facts panel on conventional food. The required nutrients, formats, and Daily Values differ between the two.
| Element | Nutrition Facts (Food) | Supplement Facts (Supplements) |
|---|---|---|
| Regulation | 21 CFR 101.9 | 21 CFR 101.36 |
| Applies To | Conventional foods and beverages | Dietary supplements (vitamins, minerals, herbs, amino acids, etc.) |
| Serving Size | Reference Amounts Customarily Consumed (RACC) | Manufacturer-defined (must be reasonable) |
| Calories | Required | Required |
| Total Fat / Sat Fat | Required | Required if present in meaningful amount |
| Sodium | Required | Required if present in meaningful amount |
| Total Carb / Sugars / Fiber | Required | Required if present in meaningful amount |
| Protein | Required | Required if present in meaningful amount |
| Vitamins & Minerals | Vit D, Calcium, Iron, Potassium required; others voluntary | All dietary ingredients with established DV must be listed |
| Daily Value (DV) | Based on 2,000 calorie diet | Based on adult daily intake; different values for some nutrients |
| Source Ingredients | Not required in panel | Required in parentheses (e.g., "Vitamin C (as ascorbic acid)") |
| Proprietary Blends | Not applicable | Must list total weight and individual ingredients in descending order |
| "Other Ingredients" | Listed after nutrition panel | Required section listing excipients, binders, fillers |
Protein powders are the most common source of confusion. If marketed as a food ingredient (e.g., "add to smoothies"), use Nutrition Facts. If marketed with structure/function claims (e.g., "supports muscle recovery"), use Supplement Facts. The FDA has issued warning letters for using the wrong panel.
FDA requires source ingredients in parentheses (e.g., 'Calcium (as calcium carbonate)'). Omitting this is a common violation.
Supplement Daily Values differ from food Daily Values for some nutrients. Using food DVs on a supplement panel is incorrect.
Proprietary blends must list total weight AND all individual ingredients in descending order by weight. Hiding ingredients is prohibited.
This is one of the most common supplement labeling violations and frequently triggers FDA warning letters.
Catch panel type errors, missing source ingredients, and incorrect Daily Values before the FDA does.
Check Supplement Label