Supplement Facts panel generator and FDA rules

The panel nobody reads until a regulator does

You are launching a new SKU. You have a formulation, a label designer, and a tight deadline. The Supplement Facts panel gets dropped onto the back of the label in the last round of artwork, mostly because you are running out of time and the ingredient list is the last piece of copy to lock. You sign off. The bottle ships.

Most Supplement Facts panels in the dietary supplement category get at least one thing wrong. Some are harmless. Some will attract an FDA warning letter. The reason is that 21 CFR 101.36, the regulation that governs the format of the Supplement Facts panel, is surprisingly specific. It dictates not just what to list, but which fonts are acceptable, which weights have to be bold, how the box rules are drawn, where the asterisk goes, and which nutrients get a percent Daily Value column at all.

This piece walks through what the regulation actually requires, the three or four mistakes brands ship most often, and how to get a compliant panel produced quickly using Kreyd free Supplement Facts generator.

What 21 CFR 101.36 actually requires

Dietary supplements use a Supplement Facts panel, not a Nutrition Facts panel. Nutrition Facts is for conventional food. That is the first distinction, and it is the one most DIY brand owners miss.

The core required elements, in order:

Heading. The words Supplement Facts appear at the top, in bold, larger than the largest nutrient name in the panel.
Serving size. The number of capsules, tablets, scoops, or millilitres that make one serving. The serving size is typographically distinct (a rule separates it from the heading, a rule separates it from the nutrients).
Servings per container. An integer, declared immediately under the serving size.
Amount per serving column header. Usually rendered as Amount Per Serving, positioned above the right numeric column.
Percent Daily Value column header. Rendered as % Daily Value, abbreviated %DV. Present only when at least one nutrient has a reference value established by the FDA.
Nutrient lines. Listed in a prescribed order: the nutrients with established Daily Values first, then dietary ingredients without established Daily Values, grouped by category.
Daily Value footnote. An asterisk next to any nutrient without an established Daily Value, and a corresponding footnote at the bottom reading Daily Value not established.
Other ingredients statement. Immediately below the panel, listing non-dietary ingredients like capsule shell materials, anti-caking agents, flavourings, binders. This is technically outside the panel, but ships with it.

Typography: bolds, regulars, italics

The regulation prescribes weights. The nutrient names are regular weight. The numeric amounts are regular weight. The heading Supplement Facts is bold. Serving Size, Amount Per Serving, and % Daily Value are bold. The asterisked daily value note at the bottom is regular.

Typefaces: the FDA permits Helvetica, Helvetica Bold, and a small set of other sans serif faces. Most brand teams go with Helvetica or a close equivalent because it is what the reference artwork in the regulation uses. A custom display face is not compliant, regardless of how well it matches the rest of the brand.

Box rules: not decorative

The panel is bounded by a rectangular black rule. Inside, horizontal rules separate the heading block from the serving size block, the serving size block from the nutrient block, and the nutrient block from the footnote block. Rule weights are prescribed in points. A panel drawn without the rules, or with decorative dotted or gradient rules, is not compliant.

Where brands get it wrong

These are the four mistakes that come up most often in retail panel audits.

Mistake one: percent Daily Value on a proprietary blend

A proprietary blend is a mixture of dietary ingredients where the brand declares the total weight of the blend, and the individual ingredients in descending order by weight, but not the weight of each individual ingredient. Proprietary blends are legal. What is not legal is declaring a percent Daily Value on the ingredients inside the blend, because individual ingredient weights have not been disclosed.

The pattern you want is: the blend has a total weight. The total weight has a %DV if a Daily Value is established for the blend category (rarely the case). Individual ingredients inside the blend list no %DV. An asterisk on every ingredient inside the blend, a footnote reading Daily Value not established.

Mistake two: missing the “Daily Value not established” footnote

Herbs, botanical extracts, amino acids, and many active ingredients used in supplements do not have FDA-established Daily Values. Each one needs an asterisk in the %DV column and a corresponding footnote at the bottom of the panel. Skipping the footnote, or skipping the asterisk on one of the ingredients, is a formatting violation the FDA will cite.

Mistake three: wrong heading for the product type

A dietary supplement uses a Supplement Facts panel. A conventional food uses a Nutrition Facts panel. Some products straddle the line (protein bars, functional beverages, meal replacement powders). The classification is not a design choice, it is a regulatory one, and it determines which panel you are legally required to use. If the product is registered as a dietary supplement with the FDA, the panel heading reads Supplement Facts. If it is a conventional food, Nutrition Facts. Using the wrong heading is a format failure even if every nutrient line is correct.

Mistake four: nutrient ordering

The regulation prescribes an order. Calories and calories from fat first (if applicable). Then fat, saturated fat, cholesterol, sodium, total carbohydrate, dietary fibre, sugars, protein. Then vitamins and minerals in a set order. Then dietary ingredients without established Daily Values. A panel that lists the ingredients in brand-convenient order (for example, putting the hero ingredient at the top for visual prominence) is not compliant.

Other common design sins

Omitting the bounding box rule (stylised panels that float on the label without a rectangle).
Using a non-compliant typeface because it matches the brand.
Inconsistent decimal precision (some values at one decimal, others at zero, others at three, with no reason).
Leaving off the Other Ingredients statement or merging it into the panel itself.
Sub-microgram values written with ambiguous units (mcg versus µg versus ug). mcg and µg are both acceptable. ug is not.

Using the free Supplement Facts generator in Kreyd

Kreyd: COA & Lab Reports ships with a free Supplement Facts generator built into the admin. The point of building it into the same app is that most brands producing a Supplement Facts panel are also producing a COA for the same batch, so the pipeline is the same set of ingredients, the same batch code, the same date. The generator walks through the required fields:

Serving unit. Capsule, tablet, scoop, millilitre. The generator renders the units consistently in the header and in the nutrient weight column.
Nutrient lines. Add each nutrient, its amount, and its unit. The generator looks up the Daily Value against the current FDA reference list (updated when the FDA publishes changes) and fills the %DV column automatically, or asterisks the row and populates the footnote if no Daily Value is established.
Proprietary blends. Declare a blend name and a total weight, then add component ingredients in descending order. The generator prevents you from typing a %DV against a component, because the regulation does not allow it.
Other ingredients. A free text field. The output prints it immediately under the bounded panel, in the right typographic style.

The output renders a printable PDF at the physical dimensions you specify, a web rendering at the correct typography for use in the product page, and a schema JSON payload you can hand to a label printer or a co-packer without additional translation.

The generator does not give legal advice. It enforces the formatting rules in 21 CFR 101.36, not the product classification decision (dietary supplement versus conventional food) which is a separate determination the brand has to make with counsel or with a regulatory consultant.

Why this sits in the same app as the COA

Supplement Facts and Certificate of Analysis are the two pieces of regulated content a supplement brand attaches to every SKU every batch. They share the same operations flow: formulate, test, produce the panel, produce the COA, ship. Most brands treat them as two independent chores handled in different tools. Keeping them in one place means the batch number shows up once, the ingredient names show up once, and the artwork and the storefront rendering stay in sync without a second round of reconciliation.

The Supplement Facts generator is free inside Kreyd: COA & Lab Reports. You do not need to publish a COA to use it. Brands that already produce their labels offline use the web generator as a validator and the JSON payload as a feed into their existing label software. Brands that do not have a label production pipeline use the PDF output directly.

Supplement Facts panel generator: free tool and FDA formatting rules