Nutrition labelling for functional drinks: the EU food rules, not the supplement panel

A manufacturer moving from supplements into functional drinks meets an early surprise: the label is governed by a different rulebook. Where a supplement carries a supplement-style panel of nutrients per daily dose, a functional drink — as a food — carries an EU food nutrition declaration, with its own mandatory content, its own format, and a per-100-ml basis. Knowing the food labeling rules is essential to getting a beverage to market. Here is the working overview.

The mandatory nutrition declaration

EU food law requires a nutrition declaration giving energy and a defined set of nutrients — fat, saturates, carbohydrate, sugars, protein and salt — expressed per 100 ml for a drink, with a per-portion column optional. This is the backbone of a food label and is different in both content and basis from a supplement panel. Software that computes this declaration from the recipe, per 100 ml, produces the correct food-law document rather than a repurposed supplement panel.

Added nutrients appear too

A functional or fortified drink adds vitamins and minerals on top of the mandatory nutrients, and these are declared as well — in elemental, delivered amounts, with their reference intake percentages where required. The declaration thus blends the mandatory food nutrients with the functional additions, all calculated from the same recipe. Holding both in one formula keeps the combined declaration accurate.

The ingredient list and allergens follow food rules

A food label requires a full ingredient list in descending order of weight, with allergens emphasized, and additives named with their function and E-number. This is more prescriptive than many supplement formats, and it derives entirely from the recipe. Generating the ingredient list and allergen emphasis from the formula keeps them correct and consistent with the actual composition.

Portion and serving basis matter

For a drink, the per-100-ml basis is mandatory, but the meaningful figure for the consumer is often the portion — the bottle or the glass. Getting the portion definition right, and deriving the per-portion figures from it consistently, keeps the label both compliant and useful. Software that reconciles fill volume, portion and per-100-ml keeps these aligned.

Claims layer on top

Any nutrition or health claim on the drink — "source of vitamin C," a permitted functional claim — has to meet its conditions against the per-100-ml or per-portion content and use permitted wording. Linking claims to the calculated content keeps them valid under the food claims framework.

Because food labeling rules are detailed and differ in application by market, confirm the current EU and national requirements for your specific drink rather than relying on a general summary.

Where Lemoniq fits

Lemoniq generates the EU food nutrition declaration per 100 ml from the recipe, blends mandatory and added nutrients with elemental amounts and reference intakes, produces the food-rules ingredient list and allergen emphasis, and links claims to the calculated content.

The takeaway

A functional drink wears a food label, not a supplement panel — a different document with mandatory nutrients, a per-100-ml basis and food-rules ingredient declarations. The manufacturers who get beverages to market cleanly are the ones whose software generates the right food-law label from the formula.

Lemoniq generates the correct EU food nutrition declaration for functional drinks straight from the recipe. We solve this exact problem. See how it works