Reading a label

Which statements are mandatory on a supplement label in Türkiye?

Article 13 of Communiqué 2013/49 requires dietary supplements to comply with the Turkish Food Codex Labelling Regulation and, in addition, to carry the following information: ^[1]

• a name characterizing the product by at least one of nutrients, botanicals and other substances;
• the daily serving amount recommended for consumption by the manufacturer;
• “Do not exceed the recommended daily serving.”
• “Food supplements cannot replace a normal diet.”
• “Keep out of the reach of children.”
• “Not a medicine. Not used to prevent or treat diseases.” (in letters at least 3 mm in “x” height);
• the statement “Consult your doctor in pregnancy and breastfeeding, and in cases of illness or medicine use.” or, if necessary for the product, a more restrictive statement;
• other warnings from the manufacturer.

TÜBER (Türkiye Dietary Guidelines) 2022 also lists the “food supplement approval number” in its label list based on the Communiqué; this line does not appear in the current text of Article 13 of the Communiqué. ^[2] The format of the approval number is set by the Ministry of Agriculture and Forestry’s approval instruction: a 6-digit number given by the provincial directorate in GGBS (the Food Safety Information System) and the approval date (“Food Supplement Approval No: 000001-day.month.year”). ^[3] The Communiqué also states that the product may be placed on the market only under the name “food supplement” and that, where ready packaging such as a sachet, blister, ampoule or bottle is sold with an outer package, the mandatory information is sought on the outer package. ^[1]

Statements about the user group are also within the legal framework. On the label of products aimed at the 2–4 or 4–10 age group, the statement “Suitable for use by children in the 2–4 age group.” or “Suitable for use by children in the 4–10 age group.” appears together with the product name; on the label of products not aimed at these groups, no shape, picture or statement implying they are meant for children may appear. ^[1] TÜBER also states that some products are suitable only for individuals over 18 and that the statement “Not for use under 18 years of age” is mandatory on the label of these products, and that some supplements may carry warnings on allergenic ingredients, conditions of use and storage, and special warnings such as “A doctor should be consulted if used for more than 3 months.” ^[2]

What cannot appear on a label?

According to the Communiqué, the label, presentation and advertising cannot carry statements saying or referring to the product having the property of preventing, treating or curing a disease; statements stating, implying or stressing that nutrients cannot be met by an adequate and balanced diet are also prohibited. ^[1] The 2023 regulation of TİTCK (Turkish Medicines and Medical Devices Agency) states that health claims cannot be vague, false or misleading, cannot be used in a way that encourages excessive consumption of a product, and that claims based on testimonials or institutional endorsement are not allowed. ^[4] TÜBER states that offering supplements for sale with statements such as body weight loss or gain, height growth, sexual performance or quitting smoking is contrary to the legislation. ^[2]

Are %NRV, RDA and UL the same thing?

No; the three concepts answer different questions. The Communiqué requires that, when vitamin and mineral information is given, the amount in the daily serving also be stated as a percentage of the nutrient reference value (NRV; Turkish BRD) in the Turkish Food Codex; for nutrients with no NRV, the statement “there is no nutrient reference value.” appears on the label. ^[1] In addition, for supplements containing vitamins and minerals, the amount in the daily serving must be at least 15% of the NRV for ages 11 and over (half of that for ages 4–10); nutrients below 15% appear only in the ingredient list. ^[1]

The RDA (recommended dietary allowance) is a reference for planning the requirements of healthy people in groups. The UL, in EFSA’s definition, is the highest chronic daily total intake of a nutrient from all sources that is not expected to cause adverse health effects. ^[5] A product with a high %NRV (for example 500%) is therefore not “better” for a person without a deficiency; and the UL is a ceiling for the habitual daily total, not for a single serving. How upper limits are calculated is in the guide Are supplements safe?.

The exactness of the figure on the label is also measured within a range. According to the Communiqué, in market controls the deviation rates relative to the label declaration are applied in the range of −20% to +50% for vitamins, −20% to +45% for minerals and −20% to +20% for other substances. ^[1] A vitamin labelled “100 mg” is therefore considered consistent with the label declaration if the value found in the control stays within this range; the range may also be assessed by the Ministry with another deviation rate declared by the manufacturer.

Form, elemental amount and the product-name trap

Three distinctions are needed to understand what the figure on the label shows.

1. Elemental amount versus compound weight. A mineral supplement is mostly in salt form; the weight of the salt and the weight of the mineral in it (elemental) are not the same. In EFSA’s upper-limit table, the value of 250 mg/day for magnesium is defined, in the table note, for “readily dissociable magnesium salts (chloride, sulfate, aspartate, lactate, etc.) and compounds such as magnesium oxide added to food supplements, water or foods,” and does not include magnesium naturally present in foods. ^[5] The elemental proportion and absorption differences of forms such as magnesium oxide and citrate are explained on a separate page.

Detailed guideMagnesium forms: oxide, citrate, glycinate and the elemental amount on the label→

2. Active substance name versus trade name. According to the approval instruction, the name of the supplement must be consistent with the active substances in its composition; in the specification document and in the label’s active-substance table, the active-substance names set in the legislation are used, not the patented names of raw materials (for example, for a product containing liposomal iron, “iron” must be written as the active substance in the table). ^[3]

3. Unit and serving. According to the same instruction, the product name may reflect the amount of active substance in the consumption unit (such as 1 capsule or 1 drop), but not the total amount in the daily intake dose; for example, if 3 capsules provide 600 mg of vitamin C, 600 mg cannot be written in the product name, while 200 mg can. ^[3] For this reason the number in the product name and the “amount in the daily serving” line are read together.

Blend products and botanical extracts

The Communiqué requires the amounts of nutrients, botanicals and other substances to be stated numerically on the label per the product’s recommended daily serving. ^[1] The specification document in the approval file also shows the nature of the active substance (such as powder or extract), its unit and its amount in the daily intake dose. ^[3] What expressions such as “root extract,” “standardized extract” or the percentage of an active component (for example withanolide, curcuminoid, EGCG) mean in extracts, and which amount was used in studies, is explained in the product guides: Ashwagandha, Curcumin, Green tea. The numerical declaration rule requires the amount of each component to appear on the label.

How are IU, µg and mg converted?

International units (IU) appear on older labels and in studies; the conversion depends on the nutrient and its form.

NIH states that for vitamin A the source must be known for RAE to be converted directly to IU. ^[7] For vitamin E, which form of α-tocopherol (natural or synthetic) is used must be read separately from the label. Because upper limits are defined according to these forms (for example, for vitamin A only preformed vitamin A, that is retinol and retinyl esters) ^[5], the comparison comes out wrong when the unit conversion is done incorrectly.

What do third-party testing certificates mean?

Some products carry the mark of an independent organization. Informed Sport, by its own definition, is a certification program showing that every batch of the product has been tested for more than 285 substances banned in sport and that the product is made under quality systems suitable for athlete nutrition. ^[8] Other organizations such as NSF (Certified for Sport) and USP also have similar third-party programs; the scope of each program is stated in its own definition. The IOC 2018 consensus statement says that athletes can use third-party auditing activities to identify low-risk products, but that there is no absolute safety guarantee for any product. ^[9] A certificate shows a defined scope, such as banned-substance screening or content verification; it does not show that the product is effective.

How is an approval number looked up?

The Ministry of Agriculture and Forestry publishes the current list of approved products through the Food Safety Information System (GGBS); the list includes the product name, company details and approval status, and products not on the list are not considered approved as food supplements. ^[10] The GGBS search screen has the fields “Manufacturer/Importer business name,” “approval number” and “product name.” According to the Ministry, approval is product-based; one product of a company being approved does not mean the others are approved. ^[10] Unapproved products or misleading claims can be reported through the Güvenilir Gıda mobile app and the ALO 174 Food Hotline. What approval does and does not cover is in the guide What are supplements?.

Checklist: which lines on a label are read together?

1. Is the number in the product name the amount in the daily serving or in one capsule?
2. How many units is the daily serving, and is the %NRV on the label given accordingly?
3. Is the mineral amount elemental or compound weight?
4. Is the same nutrient also taken from another product, a multivitamin or a fortified food? (Total intake is calculated against the upper limit.)
5. Is there a user-group warning (age, pregnancy, medicines) and a “consult a doctor” statement?
6. Is the approval number on the GGBS list?
7. Is there a disease prevention or treatment claim, a testimonial or an institutional endorsement statement? If so, this is a red flag.

For timing and medicine spacing, the guides When to take supplements and Drug interactions can be consulted. This guide does not recommend a personal product or dose.