Dietary supplements and pictograms: rules and best practices

Case study: using a pictogram on the labeling of a dietary supplement

Regulatory context

The labeling of dietary supplements is subject to strict rules, particularly those of Regulation (EC) No 1924/2006 concerning nutritional and health claims.

➡️ A pictogram must not suggest a health benefit without an authorized claim.
➡️ It must be directly related to an ingredient in the product and not exaggerate its effects.

Case study: pictogram and fatigue reduction

Problem

A company wishes to use a pictogram depicting a tired person holding an empty battery on the packaging of a dietary supplement intended to reduce fatigue.

Conforming elements

✔️ If the supplement contains an ingredient with a validated claim regarding fatigue reduction, the pictogram is authorized.
✔️ Example of a validated claim:
📝 « Vitamin C contributes to the reduction of fatigue. »

Potential problems

❌ If no approved health claim justifies the use of the pictogram, it may be considered misleading.
❌ The pictogram must not suggest an implicit claim, such as an immediate effect or a power superior to scientific reality.

Recommended correction

✔️ Accompany the pictogram with a validated claim regarding fatigue reduction.
✔️ Ensure that the font size of the claim complies with the requirements of the INCO regulation.
✔️ Avoid any graphic exaggeration that could cause confusion.

Why this correction?

In the absence of compliance:

• The product may be refused for market release.
• Warnings from authorities and fines.
• Obligation to modify the labeling under penalty of product withdrawal.

Conclusion

Pictograms are effective marketing tools, but their use must comply with current regulations. Ensure that each visual is justified by an authorized claim to avoid any sanctions.