Supplement 101

What Counts as a Drug Claim

A drug claim is any statement that suggests a product can diagnose, treat, cure, or prevent disease, which places it under drug regulatory standards.

FDAClaimsRegulation

A product is not defined as a drug by what it is.
It is defined by what is claimed about it.

In the supplement category, this distinction determines how a product is regulated.

At a high level, a claim becomes a drug claim when it suggests:

  • Diagnosis — identifying or detecting a disease or condition
  • Treatment or cure — reducing, reversing, or eliminating a disease
  • Prevention — lowering the risk of developing a specific disease

These statements place a product into the drug category, regardless of its form or ingredients.

By contrast, supplements are limited to structure/function claims —
describing how a product supports normal physiological processes.

Examples illustrate the boundary:

  • “Supports immune function” → allowed

  • “Prevents viral infection” → drug claim

  • “Helps maintain healthy cholesterol levels” → allowed

  • “Treats high cholesterol” → drug claim

The difference is often a single word.

Regulatory enforcement follows this distinction:

  • The FDA defines category boundaries based on claims
  • The FTC evaluates whether claims are truthful and substantiated

A compliant claim does not guarantee effectiveness.
A prohibited claim does not necessarily mean the mechanism is impossible.

Claims define classification.
They do not define reality.