A factory can manufacture the supplement and prepare the label, but your business may still be responsible for the information on that label and for obligations attached to placing the product on the market. The arrangement depends on which businesses are involved and what each does.
Before ordering, identify the countries where you intend to sell. Then assign the product checks, documentation and market procedures to specific parties. A promise of “EU compliance support” needs that detail to be useful.
The sales country belongs in the product brief
EU legislation provides a shared framework for food supplements. National requirements still affect the work needed to sell a particular product, including possible notification procedures and provisions concerning certain ingredients.
A formula available from a factory in one country therefore needs review for the intended destination. The review should cover the actual composition, daily amounts, label and proposed claims.
Language is part of this assessment. An English-language website does not establish that an English-only retail label is sufficient for every country where orders are accepted. Decide which markets the launch will serve before finalising artwork.
Responsibility for food information
Under Article 8 of Regulation (EU) No 1169/2011, the operator responsible for food information is the business under whose name or business name the food is marketed. If that operator is not established in the Union, the importer into the Union market has that role.
This does not make every other business in the chain irrelevant. Manufacturers, suppliers and distributors have obligations linked to their activities. The allocation needs to be understood for the actual commercial arrangement.
Your factory may provide technical help or arrange checks on your behalf. Obtain the resulting documents and confirm what was checked. The purchase of a review service should leave evidence of the work performed and the product version it covered.
Ingredients need more than a catalogue check
The Food Supplements Directive establishes lists of vitamins and minerals and their permitted sources. Other ingredients may fall under further EU or national provisions.
Novel food rules can also apply. The Commission's Novel Food status Catalogue provides orientation, but it is non-binding and does not list every possible case. Applicable authorisations and their conditions need to be considered where relevant.
Provide enough detail for the assessment. An ingredient's broad name may not identify its source, extract characteristics or production process. Intended amounts and use also matter.
The fact that an ingredient is offered for sale does not settle whether your proposed product can be marketed in the destination country. Resolve that question before committing to a batch built around it.
Review what the customer will read
The label must meet general food information requirements and the rules specific to supplements. Its review should cover the required particulars, quantities, instructions and warnings, together with language and responsible-operator information.
Review advertising at the same time. EU rules on nutrition and health claims apply to labelling, presentation and advertising, so the wording on a product page needs attention as well as the printed pack.
Check the conditions attached to any proposed claim against your product. The EU register helps identify authorised health claims and the restrictions or conditions associated with them. Some claims have a more complex regulatory status; a quick search for an ingredient name is not a complete review.
Copy supplied by the manufacturer needs the same assessment as copy written by your own business. Keep the approved wording with the product records so later advertising changes can be checked against it.
A notification is not necessarily an approval
Member States may require notification when a food supplement is placed on their market. The meaning and procedure should be checked in the relevant country.
Finland gives a useful example of the distinction. Its Food Authority explains that notification does not involve a pre-market assessment of whether the composition or labelling is lawful. Responsibility remains with the operator placing the supplement on the market.
If a supplier handles a notification, retain evidence that it has been submitted and establish whether anything further is required. Avoid presenting the notification as an endorsement by the authority.
Keep the records usable after launch
The approved specification, artwork, relevant test documents and delivery records need to remain connected to the batches sold. Preserve earlier versions when the product changes. A revised label should not make it impossible to establish what appeared on an older batch.
Set up traceability and complaint handling before the first sale. Records should allow you to connect received goods to the supplier and batch, and meet the distribution-record requirements applicable to your activities.
If a customer reports a possible problem, your business needs a route to the supplier's technical team and a way to identify affected stock. Agree how investigation and any necessary withdrawal or authority contact will be coordinated.
A practical launch record can list each outstanding requirement, its owner and the evidence of completion. Keep it tied to a specified product version and country of sale. That gives you a usable basis for deciding whether the first batch is ready to be offered to customers.
Scope and sources
This general EU overview is based on research conducted on 31 October 2026. It is not a country-specific legal assessment. Requirements depend on the formula, claims, businesses involved and destination markets; UK and US rules require separate review.
- European Commission: Food supplement framework and notifications
- Regulation (EU) No 1169/2011: Article 8 and food information responsibilities
- European Commission: Novel Food status Catalogue and its limitations
- European Commission: EU register of health claims
- Finnish Food Authority: What supplement notification means
