How to build a compliant Supplement Facts panel (21 CFR 101.36)

Flip a US supplement over and you find the Supplement Facts panel — that black-bordered box of serving sizes, amounts, and percentages. It looks straightforward, but it follows a detailed set of FDA rules, and getting it wrong is one of the most common reasons a US product is considered misbranded. Here is how a compliant panel is built.

The Supplement Facts panel, defined

US dietary supplements must carry a Supplement Facts panel, with its format and content set out in FDA regulation (21 CFR 101.36). It is the supplement equivalent of the Nutrition Facts panel on foods, but with its own rules tailored to supplements.

The panel is not free-form. The order of information, what must appear, how amounts are expressed, and how percentages are calculated are all specified.

Serving size and servings per container

The panel starts with the serving size — the manufacturer's recommended amount — and the number of servings per container. Everything else on the panel is expressed per serving, so the serving size is the anchor for the whole declaration.

Amount per serving and % Daily Value

For each dietary ingredient, the panel shows the amount per serving and, where one exists, the percentage of the Daily Value (%DV) that amount represents. The Daily Values are the US reference figures, and they were updated in recent years — which matters, because a panel using outdated reference figures is wrong.

Crucially, the %DV depends on the amount actually delivered, which depends on the ingredient form. As with any market, the physical amount drives the number on the label.

Ingredients with and without a Daily Value

Not every ingredient has an established Daily Value. The panel distinguishes between nutrients that have a %DV and those that do not — the latter are shown with their amount and a symbol indicating no DV is established. Botanicals and many specialty ingredients fall into this group, and they have their own presentation rules, including stating the part of the plant used.

Order, units, and rounding

The regulation specifies the order in which nutrients appear, the units used for each, and the rounding rules for amounts and percentages. These details are easy to get subtly wrong by hand — a unit, a rounding convention, an ordering — and each small error is a compliance defect.

Other ingredients and the rest of the label

Ingredients that are not dietary ingredients — excipients, fillers, capsule materials, flavours — are listed separately as other ingredients below the panel. Allergen information, the manufacturer or distributor details, and other mandatory elements round out a compliant label, alongside the panel itself.

Because the panel rules and Daily Values are detailed and updated over time, confirm the current FDA requirements for your specific product rather than relying on a general summary.

Why the panel drifts from the product

The Supplement Facts panel is downstream of the formula. Every dose change, ingredient swap, or serving-size adjustment should flow through to the panel — a new amount, a recalculated %DV, possibly a reordering. When the panel is maintained as a separate artwork file, it falls out of sync with the formula, and the label ends up describing a product slightly different from the one in the bottle.

Generating the panel from the formula

The reliable approach is to derive the panel from the formula data. When each ingredient carries its amount and the system applies the correct Daily Values, ordering, and rounding, the panel can be generated correctly — and regenerated whenever the formula changes. The panel becomes an output of the product rather than a document to maintain by hand.

The takeaway

A compliant Supplement Facts panel follows specific FDA rules for serving size, amounts, %DV against current Daily Values, ordering, units, and rounding — with distinct handling for ingredients that have no DV. The hard part is keeping it synchronised with a formula that changes. Generating the panel directly from formula data is what keeps the label accurate and compliant.

Lemoniq generates the Supplement Facts panel straight from your formula — correct amounts, current Daily Values, proper ordering and rounding — and regenerates it whenever the formula changes. We solve this exact problem. See how it works