bioavailability

Which words on a supplement label are legally defined, and which are just marketing?

In EU law only three things on a supplement label are regulated: the exact source name, the amount and %NRV, and any authorised claim. Bioactive, chelated, liposomal, pharmaceutical grade and natural are not defined anywhere. Here is what each word is worth, and a 60-second test for any label.

Almost none of the words that sell a supplement mean anything in law. In the European Union, three things on a supplement label are regulated: the exact chemical form of each vitamin and mineral (it has to appear by name on a closed list), the amounts and the %NRV in the nutrition declaration, and any claim about what the product does. Everything else is free text. "Bioactive", "chelated", "liposomal", "high potency", "full spectrum", "pharmaceutical grade" and "clean label" appear nowhere in EU supplement law. That does not automatically make them dishonest. It means the word is a promise from the brand, not a guarantee from a regulator, so you have to check it against the parts of the label that are regulated.

The short answer

Read a supplement label as two documents printed on the same box. One is legal text: the ingredient list with the precise source name, the amount per daily portion, the %NRV, and any authorised claim. The other is advertising: the adjectives. The legal text can be checked in a public database in under a minute. The advertising cannot be checked at all, because there is nothing to check it against.

This article maps which words fall into which document, using the actual regulations, and ends with a test you can run on any label, including ours.

What EU law actually controls on a supplement label

Three separate pieces of law do the work, and they control three different things.

1. The composition layer: which forms are even allowed

Directive 2002/46/EC on food supplements works with a positive list. Annex II names every vitamin and mineral source that may legally be used to manufacture a food supplement in the EU, and the list was rewritten and extended by Regulation (EC) No 1170/2009. If a chemical form is not on that list, it may not be used. This is the most concrete, least discussed fact about supplement labels: the specific salt behind the mineral is regulated by name.

So "zinc bisglycinate", "zinc picolinate", "zinc oxide", "magnesium bisglycinate" and "magnesium citrate" are all legally recognised terms, because each appears verbatim in Annex II. The umbrella word "chelated" does not appear in the Directive even once.

2. The numbers layer: amounts and %NRV

Regulation (EU) No 1169/2011 sets the Nutrient Reference Values in Annex XIII: 375 mg for magnesium, 10 mg for zinc, 14 mg for iron, 150 µg for iodine, and so on. Those figures are fixed in law, which is why %NRV is the only number on a label that means exactly the same thing on every product in every EU country. If you want the full explanation of what that percentage does and does not tell you, we wrote a separate piece on what %NRV actually means.

3. The claims layer: what the product is allowed to say it does

Regulation (EC) No 1924/2006 governs nutrition and health claims. A health claim may only be used if it has been authorised and listed, mostly through Regulation (EU) No 432/2012, and every authorised claim with its exact permitted wording sits in the public EU Register of nutrition and health claims. This is why compliant labels sound oddly formal: "contributes to normal energy-yielding metabolism" is the wording the law allows, while "boosts your energy" is not.

A magnifying lens resting on a blank cream paper strip on a sand-coloured surface, soft daylight
The regulated part of a label is small, specific and checkable. The rest is copywriting.

"Chelated": an empty word standing next to a precise one

Chelation is a real chemical concept: a mineral ion held by an organic molecule, often an amino acid such as glycine. The claim attached to it is that the mineral survives the gut better and is absorbed more efficiently than a simple inorganic salt.

Legally, though, "chelated" is worth nothing. It is not defined in Directive 2002/46/EC, it is not a nutrition claim under Regulation (EC) No 1924/2006, and no authorised health claim depends on it. What is regulated is the name directly underneath it in the ingredient list.

The evidence is also less tidy than the marketing suggests. In a randomised, double-blind comparison of magnesium preparations, magnesium citrate came out more bioavailable than the amino acid chelate that was tested alongside it (Walker and colleagues, 2003). In an earlier human study, zinc picolinate was absorbed better than zinc citrate and zinc gluconate over four weeks (Barrie and colleagues, 1987). Two honest conclusions follow. First, form genuinely matters. Second, "chelated" as a category does not reliably beat everything else, so the word alone predicts nothing. Our longer breakdown of the evidence per compound is in which form of magnesium is best absorbed.

What to do with it: ignore the adjective, read the salt. "Magnesium bisglycinate 100 mg" tells you something. "Chelated magnesium" on its own tells you nothing, because it does not say which chelate, or how much elemental mineral you actually receive.

"Bioactive": scientifically meaningful, legally empty

"Bioactive" (also sold as "active", "coenzymated" or "body-ready") points at something real. Several vitamins circulate in the body as coenzyme forms, and the supplement can supply either a precursor or that active form directly: methylcobalamin instead of cyanocobalamin for B12, pyridoxal-5-phosphate instead of pyridoxine for B6, L-5-methyltetrahydrofolate instead of folic acid. We explain the biochemistry, and the honest limits of it, in methylcobalamin versus cyanocobalamin.

What "bioactive" does not have is any legal status. No regulation defines it, no threshold governs it, and nothing stops a product from printing "bioactive complex" on the front while using the cheapest precursor forms inside. The word is verifiable only through the ingredient list.

What to do with it: turn the box over. If the panel says methylcobalamin, P-5-P and L-5-MTHF, the claim is backed. If it says cyanocobalamin, pyridoxine hydrochloride and folic acid, the front of the box was decoration.

"Liposomal": the one marketing word EU law has an opinion about

Liposomal supplements enclose the nutrient in a phospholipid shell, with the promise of surviving digestion and delivering more into the blood. Here the law is unusually interesting, because EU novel food legislation names the technology directly. Regulation (EU) 2015/2283 states that the definition of novel food may also cover food consisting of certain micelles or liposomes, and it treats a production process that was not used in the EU before 15 May 1997, and that significantly changes the composition or structure of a food, as grounds for novel food status. In other words, "liposomal" is not a protected marketing term, but the way a liposomal product is made can trigger a formal authorisation route.

The evidence deserves the same care. A double-blind, placebo-controlled trial published in 2024 found that liposomal delivery increased absorption of vitamin C into plasma and leukocytes. An earlier small crossover study reported modestly higher circulating vitamin C from a liposomal formulation than from an unencapsulated one (Davis and colleagues, 2016). But a 2025 scoping review that gathered the liposomal vitamin C literature concluded that the evidence base is limited and inconsistent, with small samples and varied methods, and set out what future research still has to answer.

So: promising for vitamin C, largely unproven for most other nutrients that carry the label, and completely silent about dose. A liposomal product with a low dose is still a low dose.

Macro photograph of a single translucent sphere suspended in still dark water with a fine luminous halo
A delivery format is a hypothesis about absorption, not a substitute for the amount on the label.

The words that mean nothing at all

Some terms have no definition anywhere in EU food law, which means they cannot be checked, only trusted.

  • Pharmaceutical grade. No such category exists for food supplements. Purity criteria for permitted sources come from the Directive and its implementing rules, not from a "grade" a brand awards itself.
  • Full spectrum. Undefined. It can mean a genuine multi-compound blend or a token pinch of extras.
  • Clean label. A consumer-marketing idea, not a legal standard. Read the excipient list instead.
  • High potency and high strength. Undefined for supplements. Note the contrast with "high in [vitamin]", which is a regulated nutrition claim with a threshold.
  • Natural. This is the sharpest example. EU law does define "natural", but only for flavourings, in Regulation (EC) No 1334/2008. There is no equivalent definition for a vitamin, a mineral or a plant extract in a capsule.

None of this makes such products bad. It makes the words uninformative, which is a different problem: they occupy the space where a number should be.

The words that do carry a legal threshold

A short list of label phrases is regulated, with conditions attached.

  • "Source of [vitamin or mineral]". Allowed only when the product contains a significant amount, which is set at 15% of the NRV per 100 g or, for a single portion pack, 15% of the NRV per portion.
  • "High in [vitamin or mineral]". The same system at twice the level.
  • Any health claim. Permitted only in authorised form, from the EU Register. If a phrase describing an effect on the body is not in that register in some recognisable wording, it should not be on the label.
  • The nutrition declaration itself. Amount per portion plus %NRV, both defined by Regulation (EU) No 1169/2011.

The 60-second label test

You can apply this to any supplement, from any brand.

  1. Find the daily portion, then the amount. Not per capsule: per recommended daily portion. Two capsules at 125 mg is not stronger than one at 250 mg.
  2. Read the source name, not the adjective. "Zinc picolinate" is checkable against Annex II of Directive 2002/46/EC. "Chelated zinc" is not.
  3. Check the elemental amount. A mineral salt weighs far more than the mineral inside it, so the number that matters is the elemental figure, usually the one carrying the %NRV.
  4. Look up the effect claim. Search the wording in the EU Register of nutrition and health claims. Authorised wording is dry and specific. Vivid wording usually means no authorisation exists.
  5. Ignore any adjective with no number behind it. If removing the word changes nothing you can verify, it was there to sell, not to inform.
Two small heaps of mineral crystals side by side on a sand-toned surface under raking light, one coarse and one fine
Two heaps, one mineral, different salts. The label word is optional. The salt name is not.

How this applies to our own labels

The test is only worth writing down if it survives being pointed at us.

We use the word "bioactive" on our Bioactive Vitamin B-Complex. It carries no legal weight, so the only thing that justifies it is the panel: methylcobalamin for B12 and L-5-MTHF folate, alongside the other B vitamins in their active forms, plus choline and inositol. B vitamins such as B1, B2, B3, B5, B6, B12, biotin and folate contribute to normal energy-yielding metabolism and to the reduction of tiredness and fatigue. That claim is authorised. The word "bioactive" is not, and you should treat it as a summary of the ingredient list, nothing more.

Our Zinc Picolinate Capsules deliver 30 mg of elemental zinc as zinc picolinate, a source named in Annex II. We do not describe it as "chelated", because the salt name is more informative than the category. Zinc contributes to the normal function of the immune system, to normal DNA synthesis and to the protection of cells from oxidative stress.

Our Magnesium 7 in 1 provides 251 mg of elemental magnesium across seven complementary compounds. Seven forms is a formulation choice, not a legal category, and it does not make the product exempt from the arithmetic: the elemental figure is what counts, which is why it is printed.

None of us can make a marketing word regulated. What a brand can do is make sure every word on the front is answerable by something on the back.

Frequently asked questions

Is "chelated" a legally protected term in the EU?
No. It appears nowhere in Directive 2002/46/EC or in Regulation (EC) No 1924/2006. What is regulated is the specific source name, such as magnesium bisglycinate or zinc bisglycinate, each of which is listed in Annex II of the Directive.

Does "bioactive" guarantee active vitamin forms?
No. It has no legal definition and no threshold. The only proof is the ingredient list: look for methylcobalamin, pyridoxal-5-phosphate and L-5-methyltetrahydrofolate rather than cyanocobalamin, pyridoxine and folic acid.

Are liposomal supplements better absorbed?
For vitamin C there is supportive evidence, including a 2024 double-blind placebo-controlled trial, but a 2025 scoping review found the overall literature limited and inconsistent. For most other nutrients sold as liposomal, comparable human evidence is thin. The format also says nothing about the dose.

Does "pharmaceutical grade" mean a supplement is purer?
It has no meaning in EU food law. Purity requirements come from the permitted sources in Annex II and their purity criteria. If purity matters to you, ask for a certificate of analysis rather than trusting the phrase.

What does "source of" a vitamin legally require?
At least a significant amount, defined as 15% of the Nutrient Reference Value per 100 g, or 15% of the NRV per portion when the pack contains a single portion. "High in" requires twice that.

How can I check whether a claim on a label is allowed?
Search the wording in the EU Register of nutrition and health claims, kept by the European Commission. Authorised claims are listed with the nutrient and the permitted phrasing.

The Bottom Line

The regulated part of a supplement label is narrow but genuinely reliable: the source name, the amount, the %NRV, and any authorised claim. The persuasive part is unregulated and, for the most part, unverifiable. "Chelated" has no legal definition but sits above a salt name that does. "Bioactive" describes real chemistry that only the ingredient list can confirm. "Liposomal" is the rare marketing word that EU novel food law explicitly notices, while the human evidence behind it remains narrow. Judge a product on the numbers it commits to, and treat every adjective as a claim waiting to be checked. That habit works on every brand, ours included.

Sources

  1. Directive 2002/46/EC on food supplements, consolidated text including Annex II (permitted vitamin and mineral sources). European Parliament and Council, consolidated 2017.
  2. Regulation (EC) No 1170/2009 amending Annexes I and II of Directive 2002/46/EC. European Commission, 2009.
  3. Regulation (EC) No 1924/2006 on nutrition and health claims made on foods, including the Annex conditions for "source of" and "high in". European Parliament and Council, 2006.
  4. Regulation (EU) No 1169/2011 on food information to consumers, Annex XIII (Nutrient Reference Values and the 15% significant amount rule). European Parliament and Council, 2011.
  5. Regulation (EU) No 432/2012 establishing a list of permitted health claims made on foods. European Commission, 2012.
  6. EU Register of nutrition and health claims made on foods. European Commission, Food and Feed Information Portal.
  7. Regulation (EU) 2015/2283 on novel foods, including the statement that the definition may cover food consisting of certain micelles or liposomes. European Parliament and Council, 2015.
  8. Regulation (EC) No 1334/2008 on flavourings, the one place EU food law defines the term "natural". European Parliament and Council, 2008.
  9. Walker AF, Marakis G, Christie S, Byng M. Mg citrate found more bioavailable than other Mg preparations in a randomised, double-blind study. Magnesium Research, 2003.
  10. Barrie SA, Wright JV, Pizzorno JE, Kutter E, Barron PC. Comparative absorption of zinc picolinate, zinc citrate and zinc gluconate in humans. Agents and Actions, 1987.
  11. Davis JL, Paris HL, Beals JW, et al. Liposomal-encapsulated ascorbic acid: influence on vitamin C bioavailability and capacity to protect against ischaemia reperfusion injury. Nutrition and Metabolic Insights, 2016.
  12. Liposomal delivery enhances absorption of vitamin C into plasma and leukocytes: a double-blind, placebo-controlled study. European Journal of Nutrition, 2024.
  13. Do liposomal vitamin C formulations have improved bioavailability? A scoping review identifying future research needs. Basic and Clinical Pharmacology and Toxicology, 2025.
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