Structure/Function Claim: Reading a Supplement Label
[Glossary · Quality, storage and rules]

Structure/function claim

Also called structure-function claim, supports healthy claim, FDA disclaimer · Reviewed

Definition: A structure/function claim is a statement on a dietary supplement label about how an ingredient affects the normal structure or function of the body, such as supporting bone health. Federal rules (21 CFR 101.93) allow these claims only if they are not disease claims and carry an FDA disclaimer.

The disclaimer you see on the bottle

When a label makes one of these claims, the rule requires this disclaimer, in bold type at least one-sixteenth of an inch high:

This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.

It sits next to the claim or is linked to it with a symbol such as an asterisk. The maker must also notify FDA within 30 days of first marketing the product with the claim, and certify it has evidence that the claim is truthful and not misleading.

What turns it into a disease claim

The rule defines a disease as damage to an organ or body system so it does not work properly, or a state of health leading to that, such as high blood pressure. A statement becomes a disease claim if it says or implies, among other things, that the product:

  • affects a specific disease or its typical signs or symptoms;
  • substitutes for a drug or therapy for a disease;
  • boosts a particular therapy or drug action for a disease;
  • does so through its name, pictures or cited studies.

A supplement label that makes a disease claim is regulated as a drug, unless it is an authorized health claim.

Why it matters for your log

The claim tells you what the maker is allowed to say, not what FDA has checked. When you log a supplement in Dose Track, note what you are taking it for in your own words, so you and your prescriber can judge whether it is doing anything.

Read more on Dose Track: Black cohosh vs red clover · Saw palmetto vs finasteride · 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

Does FDA approve structure/function claims?+
No. The required disclaimer says the statement has not been evaluated by FDA. The maker notifies FDA and must have substantiation, but FDA does not approve the claim first.
Can a supplement say it treats a disease?+
Not as a structure/function claim. Under 21 CFR 101.93, a product with a disease claim is regulated as a drug unless the claim is an authorized health claim.