Why “not making false claims” isn’t enough in the EU
Most people who sell supplements in Europe believe the rule is: don’t lie. Don’t promise a cure, don’t invent research, don’t say something you can’t back up. That instinct is right about everything except the part that gets shops into trouble.
Under Regulation (EC) 1924/2006, a health claim is not assessed on whether it is true. It is assessed on whether it appears on the Union register of permitted claims, and whether you have used the wording that the register uses. A claim can be scientifically sound, honestly meant, and still prohibited — because it is not on the list, or because it is on the list and you paraphrased it.
The paraphrase problem
“Supports your immune system” is the single most common sentence in supplement copy. It is also not a permitted claim. The permitted version is “Vitamin C contributes to the normal function of the immune system” — and it is only permitted on a product that actually contains vitamin C in a meaningful amount.
The shorter sentence is not a softer version of the longer one. It is a different claim: it names no nutrient, it promises support rather than a contribution to normal function, and it applies to the product rather than to an ingredient. Every one of those differences matters to a regulator.
Conditions travel with the claim, too. Where the register attaches a dose — melatonin’s effect on the time taken to fall asleep applies at 1 mg close to bedtime — dropping the dose from the sentence drops the permission with it.
The ingredients with nothing to say
The harder case is the ingredient that has no authorised claim at all. Not a stricter wording — none. For these, there is no compliant way to describe an effect, because no effect has been authorised. The only lawful copy is factual: origin, form, dose, quality, taste.
Across the two catalogues we ran through the engine — 13,933 products between them — these are how many products contain an ingredient in exactly that position:
| Ingredient | Products containing it |
|---|---|
| Caffeine | 614 |
| Collagen | 537 |
| Glucosamine | 298 |
| Turmeric | 297 |
| MSM | 228 |
| Probiotics | 213 |
| BCAA | 178 |
None of these ingredients may carry a health claim in the EU today. That does not make them unsellable, and it does not make the products bad. It means the copy has to do its work with facts instead of promises — which is harder to write, and completely legal.
What this means for a catalogue
If your listings were written by people trying to be honest, you will still have findings — often thousands of them. That is not a sign of bad intent. It is a sign that the rule being followed was “don’t lie” rather than “use the register’s words”, and those two rules produce very different sentences.
A text with no claim is always permitted. An unauthorised claim never is. When in doubt, leave it out.
You can check a single product against these rules without an account. Paste a title and a description into the scanner and you get the risk score, every finding, and the rule behind each one.