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Structure/Function Claims Explained With Examples

If you sell dietary supplements, structure/function claims are the main kind of benefit statement open to you without FDA approval. The line between one of these and a disease claim is narrow, and it runs through ordinary product copy. This guide explains the definition, the conditions and some examples. This is general information, not legal advice.

What a structure/function claim is

According to the FDA, a structure/function claim describes the role of a nutrient or dietary ingredient intended to affect the normal structure or function of the human body. It can also describe how the ingredient acts to maintain that structure or function.

The FDA gives these examples:

Each one names a normal body function. None of them names a disease.

Where it becomes a disease claim

The FDA says only a drug can legally make a disease claim. A supplement that claims to diagnose, treat, cure or prevent a disease has crossed the line, whatever the rest of the page says. The regulation that separates the two is 21 CFR 101.93.

Structure/function claimDisease claim
Calcium builds strong bonesTreats osteoporosis
Fiber maintains bowel regularityRelieves chronic constipation
Supports a healthy immune systemPrevents colds and flu

A useful test: if the sentence names a condition a doctor would diagnose, or implies the product fixes one, treat it as a disease claim.

The conditions that come with it

The FDA does not pre-approve structure/function claims, but a supplement that uses one has three obligations.

Supplements versus conventional foods

The rules differ if your product is a conventional food instead of a supplement.

Watch the whole page

A carefully worded claim can be undone by what sits around it. As a cautious practice, review the product name, images and featured testimonials along with the description, and treat the items below as red flags to check.

Advertising is also covered by the FTC, which expects health claims to be supported by competent and reliable scientific evidence. See supplement claims under the FDA and FTC and cosmetic versus drug claims for more.

Doing this at scale

ContentGuard scans your product descriptions and classifies each claim as safe, risky or prohibited against the rule profile you choose, such as US Dietary Supplement. It cites the governing FDA or FTC rule, scores each page, and proposes a rewrite you can apply in one click. It is a screening tool, not a substitute for legal review. See ContentGuard.

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