Structure/Function Claims and the DSHEA Disclaimer
The workhorse supplement claim and its required DSHEA disclaimer, the 30-day FDA notification, and a copy-ready disclaimer (plus a combined affiliate version).
Structure/function claims are the workhorse of supplement marketing, and they come with a specific, non-negotiable disclaimer under DSHEA. If your affiliate content makes or repeats a structure/function claim, the disclaimer needs to appear.
What a structure/function claim is
A structure/function claim describes how a nutrient or dietary ingredient affects the normal structure or function of the body, or the mechanism by which it maintains that structure or function. Examples: “calcium builds strong bones,” “supports a healthy immune system,” “helps maintain normal cholesterol levels already within the normal range.” Crucially, these describe normal function — not treatment of a disease.
The three DSHEA duties
- Substantiation: the claim must be truthful, not misleading, and supported by adequate evidence.
- FDA notification: the manufacturer must submit the claim text to the FDA within 30 days of first marketing.
- The disclaimer: the label (and, in practice, advertising that makes such claims) must carry the DSHEA disclaimer.
The required disclaimer wording
The disclaimer is set by DSHEA and codified at 21 CFR 101.93. Copy it below:
The FDA-required wording for structure/function claims (21 CFR 101.93). Use it verbatim wherever such a claim appears.
Combined affiliate + DSHEA disclosure
On an affiliate page, pair the DSHEA disclaimer with your affiliate disclosure and a “not medical advice” line. Here is a ready-to-use combined block:
Educational sample, not legal advice. Place it prominently, before your affiliate links.
Placement and prominence
Like any disclosure, the DSHEA statement must be noticeable, not buried. On the label it is linked to the claim; in advertising, follow the FTC’s clear-and-conspicuous standard so the reader actually sees it.
For the broader claim framework, see the three types of supplement claims; for the advertising-evidence standard, see FTC substantiation.
Authoritative sources
Last reviewed July 2026. This page is general educational information, not legal or tax advice.