Review claim wording without hiding uncertainty

Claims to include

Published starting point

FDA explains the distinction and notification process for dietary supplement structure/function claims. Read the FDA structure/function claims guidance and verify the current rule before acting.

Check the complete communication

Copy the claim exactly as consumers see it and include the product name, headline, surrounding copy, images, testimonials, asterisks, and linked footnotes. “Supports healthy joints” and “treats arthritis” do not present the same regulatory question, while a product name or testimonial can change the meaning of otherwise general wording. Review label and digital uses separately because placement and audience can differ.

The result should preserve three layers: the submitted wording, the automated classification signal, and the rule finding with its source. If context is missing or classification remains uncertain, keep the item open for qualified review rather than editing the wording until a warning disappears.

Before approving a claim

1. Confirm the exact statement and every qualifier on the final artwork.
2. Check whether the wording expressly or implicitly refers to disease.
3. Match substantiation to the actual product, dose, population, and conditions of use.
4. Review any required disclaimer and notification as separate obligations.
5. Recheck marketplaces, ads, social posts, and affiliate copy for inconsistent language.

For presentation rules, also consult 21 CFR 101.93.