Retail supplement packaging and label copy under editorial studio lighting

Claims & Labelling

Your formula is usually compliant.
Your copy is where the risk is.

Your formula is usually compliant.
Your copy is where the risk is.

Your formula is usually compliant.
Your copy is where the risk is.

Product classification follows the whole product: the formula, the intended use, the label copy, the imagery and the advertising. A compliant formula described in therapeutic language becomes a different regulatory category, with a different approval pathway and a different set of obligations.

That reclassification happens in marketing, not in the lab, and it is usually avoidable without changing the product at all.

Common failure modes

Where claims go wrong

Where claims go wrong

01

01

Words that imply a physiological effect

Words that imply a physiological effect

Relief, recovery, treatment, anti-inflammatory. These communicate therapeutic intended use regardless of what is in the formula or at what level.

02

02

Qualifiers doing work they cannot do

Qualifiers doing work they cannot do

A footnote does not cure a misleading headline. If the main message communicates a therapeutic effect, small print below it does not reverse that.

03

03

Claims transferred from the wrong evidence

Claims transferred from the wrong evidence

A pharmacokinetic result from a fasting capsule study does not automatically support a claim on a finished food product. The ingredient data and the product data are two different things, and only one of them is about what you are selling.

04

04

Specification claims made before testing

Specification claims made before testing

A grade or content claim printed before finished-product testing confirms it is a compliance exposure even when the number turns out to be right.

The mechanism

Reclassification happens in marketing, not in the lab.

Reclassification happens in marketing, not in the lab.

A compliant formula described in therapeutic language becomes a different regulatory category, with a different approval pathway and a different set of obligations. The product does not have to change for that to happen, and it does not have to change to prevent it either.

Most of this exposure is removable at the copy stage, at a fraction of the cost of removing it after artwork is signed off.

The method

What we do

What we do

01

01

A claim-by-claim status matrix

A claim-by-claim status matrix

Every term you intend to use is assessed individually and marked with the reasoning behind it. Where a term fails, we supply a compliant alternative that keeps the consumer appeal.

Allowed

Allowed with qualification

Conditional

Do not use

02

02

Substantiation mapping

Substantiation mapping

For each claim you want to keep, we identify what evidence supports it and where the evidence stops. Claims that need finished-product work to be defensible are flagged before they reach artwork.

03

03

Label and artwork review

Label and artwork review

Ingredient declarations, mandatory statements, format requirements and the interaction between copy, imagery and prominence. Artwork is reviewed as a whole, because context changes the meaning of otherwise acceptable words.

04

04

Endorsement conditions

Endorsement conditions

Where a professional recommendation is used, we set out what the endorsement file has to contain and how the qualifier must be worded.

Artwork and design references laid out for a label review

Coverage

Markets

Markets

We assess claims against the framework that will actually apply to the pack in each market you intend to sell in.

Health Canada NNHPD

FDA and DSHEA

European Union

TGA Australia

Cosmetic frameworks

BIS where relevant

Review your claims before artwork.

Review your claims before artwork.

A claim matrix is fast, scoped and cheaper than a reprint. The best time to run it is while the copy is still a document, before it becomes a print file.