Perhaps it was less being a food scientist, and more a “technical, smart ass” (as my dad would say).
In case you’re a Target Cartwheel shopper, you’ll be happy to know that until March 31, 2018, you get a “FREE $10 Target Gift Card with a food and/or beverage purchase of $50 or more.”
So, imagine my disappointment ringing up my $50+ in protein powders and bars (aka food) only to have the coupon not work.
“Mam, I can’t explain why this coupon isn’t working. You’ll have to go to customer service.”
Get to customer service –
“I’m not sure why this isn’t working. It claims it only excludes candy, baby food & formula, pet food, Target Café and Starbucks Café.”
The associate responds:
“Ahhh! I see what happened here. This is actually a supplement. We can’t give you that coupon.”
“First of all, I’m a cute girl asking nicely. Just give it to me, male Target associate.”
“Actually – it’s a food product. It has a Nutrition Facts Panel, and not a Supplement Facts Panel. Technically, this is not a supplement. Also, personally, it is my food.”
I got the gift card.
It’s about the small wins. But on a serious note – do you know the difference?
Here’s why it matters.
This decision between a Supplement Facts Panel and Nutrition Facts Panel can significantly influence a brand’s sales and marketing strategy for at least these reasons:
1. Product placement in retail environments.
2. Use of function, general well-being, and nutrient deficiency claims.
3. The standard of verifying statements and claims, translating to time and service costs.
The many criteria per Facts Panel greatly exceed the scope of this article, but here’s a quick way to rule out whether you want to move forward with a Nutrition Facts Panel as opposed to a Supplement Facts Panel.
Supplement vs. Nutrition Facts Panel.
Products featuring a Supplement Facts Panel are composed of ingredients considered “dietary ingredients.” These ingredients are not necessarily GRAS (Generally Recognized As Safe).
Products featuring a Nutrition Facts Panel are composed of ingredients pre-approved by the FDA and/or of GRAS status. These products can also contain “dietary ingredients” (found in supplements), provided they are GRAS at standardized levels. For an example, see "For example, caffeine" below.
The Federal Food, Drug, and Cosmetic Act defines a dietary ingredient as:
"a vitamin; mineral; herb or other botanical; amino acid; dietary substance for use by man to supplement the diet by increasing the total dietary intake; or a concentrate, metabolite, constituent, extract, or combination of the preceding substances."
For Example, Caffeine.
Caffeine is a dietary ingredient, though GRAS at specific limits. According to [21CFR182.1180], caffeine content is not to exceed 0.02% of a formulation (GRAS).
An ingredient fits into one or more of the following categories: food, food additive, drug, dietary supplement, GRAS ingredient. The category of an ingredient in-part determines whether a Supplement Facts Panel or Nutrition Facts Panel is recommended or required.
What This Means For You.
Before you move forward on a product development project, research the GRAS status of all intended ingredients. With the rise in specialty nutraceuticals in the traditional medicinal space, this is an important step – saving you from wasted time at the least, product recall at the worst (that is a bad "worst").
You can read more about the specific differences between a Nutrition Facts Panel and Supplement Facts Panel here.
1. FDA: Dietary Supplement Labeling Guide: Chapter IV. Nutrition Labeling
2. FDA: Dietary Supplement Products & Ingredients
3. FDA: Generally Recognized As Safe (GRAS)
4. NIH: Dietary Supplements, Background Information