The Three Types of Dietary Supplement Claims
Health claims, nutrient content claims, and structure/function claims — each with its own rules — plus the prohibited disease-claim line that triggers enforcement.
DSHEA and FDA rules allow dietary supplements to carry three broad categories of claims, each with its own requirements. Understanding the difference is the core of supplement compliance, because the line between a permitted claim and a prohibited disease claim is exactly where enforcement happens.
1. Health claims
A health claim describes a relationship between a substance and a reduced risk of a disease or health-related condition (for example, calcium and osteoporosis). These are the most tightly controlled:
- Authorized health claims must meet the FDA’s “significant scientific agreement” standard and are pre-approved by regulation.
- Qualified health claims cover emerging evidence that does not meet that standard; the FDA permits them only with qualifying language that signals the evidence is limited.
2. Nutrient content claims
These characterize the level of a nutrient using defined terms such as “high,” “free,” “low,” or “reduced” (for example, “high in vitamin C”). They rely on established Daily Values and defined terms rather than individual notification.
3. Structure/function claims
These describe the role of a nutrient or ingredient in the normal structure or function of the body (for example, “supports immune health” or “calcium builds strong bones”). They do not require pre-approval, but they carry three duties: the manufacturer must notify the FDA within 30 days of marketing, must hold substantiation, and must display the DSHEA disclaimer. See structure/function claims and the disclaimer.
The bright line: disease claims are prohibited
A supplement may not claim to diagnose, treat, cure, mitigate, or prevent a disease — those are drug claims. “Supports joint health” is a structure/function claim; “treats arthritis” is an illegal disease claim. No disclaimer rescues a disease claim.
What this means for affiliates
As an affiliate, your safest position is to stay within accurate structure/function language, avoid any disease claim (explicit or implied — including through product names, images, or testimonials), and never promise outcomes the evidence does not support. Implied disease claims are a frequent enforcement trigger: a graphic of a diseased organ or a testimonial about curing a condition can convert a lawful claim into an unlawful one. The advertising side of this is governed by the FTC substantiation standard.
Authoritative sources
Last reviewed July 2026. This page is general educational information, not legal or tax advice.