Dietary Supplement: The Legal Definition in Plain Words
[Glossary · Quality, storage and rules]

Dietary supplement

Also called supplement, DSHEA definition · Reviewed

Definition: A dietary supplement, under US law (21 U.S.C. 321(ff)), is a product intended for ingestion to supplement the diet that contains one or more dietary ingredients, such as a vitamin, mineral, herb or amino acid. It must be labeled as a dietary supplement and is legally treated as a food, not a drug.

What the law counts as a dietary ingredient

The statute lists six kinds:

  • a vitamin;
  • a mineral;
  • an herb or other botanical;
  • an amino acid;
  • a dietary substance used to supplement the diet by increasing total dietary intake;
  • a concentrate, metabolite, constituent, extract or combination of any of these.

The product must be intended for ingestion, must not be presented as a conventional food or as the only item of a meal, and must be labeled as a dietary supplement.

When an ingredient cannot be a supplement

The same section says a dietary supplement does not include an article approved as a new drug or licensed as a biologic, or one in substantial, public clinical trials as a drug, unless it was marketed as a supplement or food first. This is one reason injectable peptides sold online are not dietary supplements: they are not taken by mouth, and some are approved drug ingredients. Many are labeled research use only instead.

Why it matters for your log

Supplements do not carry an FDA-approved label like a prescribing information document, so there are no trial side-effect tables to check against. Logging the brand, the amount on the label and the start date gives you and your prescriber a record if something changes. Dose Track lets you add supplements next to prescribed medicines so the timeline stays in one place.

Read more on Dose Track: Ashwagandha vs rhodiola · Berberine vs metformin · Side-by-side comparisons

General education drawn from labels and published studies, not personal medical advice. Your prescriber, pharmacist and the label that came with your product are the final word.

Frequently asked questions

Is a dietary supplement a food or a drug under US law?+
A food. 21 U.S.C. 321(ff) says a dietary supplement is deemed to be a food for most purposes of the federal food and drug law.
Can an injectable peptide be a dietary supplement?+
No. The legal definition covers products intended for ingestion, and it excludes approved drug ingredients that were not marketed as a supplement or food first.