Selling supplements online: claims, the FDA statement and label photos

"Supports restful sleep" and "treats insomnia" sound close. Under US law they are far apart. The first is a structure/function claim, allowed with a set statement beside it. The second claims to treat a disease, and that turns your supplement into an unapproved drug. Most supplement listings that come down fall on the wrong side of that line, often in an image or a search term rather than the title.

This page covers the claims you may make, the statement that must go with them, the label photos marketplaces now ask for, and the approvals on Amazon, Walmart, Etsy, eBay, in Canada and in the EU.

What this page covers: vitamins, minerals, herbal and sports supplements, protein powders, gummies and probiotics.

The short version

• Never say a supplement treats, cures, mitigates or prevents a disease, anywhere in the listing.
• A structure/function claim needs the FDA statement word for word.
• Images make claims too. Regulators read the whole listing, images and product name included.
• Amazon wants real photos of the full label, Supplement Facts panel included, and no AI-generated label images.
• Walmart restricts supplements to vetted sellers, and Canada needs a Natural Product Number before you sell.

Which claims may a supplement listing make?

A supplement listing may make a structure/function claim with the FDA statement, but never a disease claim. A claim that a supplement treats, cures, mitigates or prevents a disease makes it an unapproved drug in the eyes of US law. Walmart and Amazon apply the same line, and both bar disease words in titles, bullets, images and search terms.

A structure/function claim describes how an ingredient affects the body's normal working: "supports restful sleep", "helps maintain healthy joints". It is allowed, but it needs this statement with it:

This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.

Some quick checks for your copy:

Can supplement images make health claims?

Yes. US regulators judge an ad by the whole impression it leaves, images and product name included. An image of a heart beside a fish oil capsule, or a before-and-after body, can make a health claim that needs evidence behind it, even when the words are careful.

What does Amazon ask of supplement images?

Amazon asks for supplement listing images that show the full label, including the complete Supplement Facts panel, and that are not computer-drawn or AI-generated, as relayed by a labelling firm that read the help page. Ingredient and amount claims in the listing must match the panel exactly. These were enforced from 31 March 2026.

Photograph the back panel straight on, in good light, readable at full size, and use that photo as it is.

Which approvals do supplements need?

Walmart, Amazon, Canada and the EU each set approvals or documents for supplements:

• Walmart restricts supplements to vetted sellers. Labels, product information and images must be in English and must agree with each other. Structure/function claims need the FDA statement, and disease claims, HCG, hemp, CBD and products that need refrigeration are barred.
• Amazon applies its dietary supplement policy, with the label image rules above.
• Canada treats supplements as natural health products. Each needs a Natural Product Number on the label before it is sold.
• The EU allows only authorised health claims, and food supplements must carry the labelling its directive sets out.

How do the marketplaces' supplement rules compare?

Amazon's, Walmart's, Etsy's and eBay's supplement rules, side by side:

What does a supplement need in Canada?

A supplement label needs a Natural Product Number before the product is sold in Canada. A US label without one is not ready for Amazon.ca.

What does a supplement need in the EU?

In the EU, only authorised health claims may be used, and food supplements must carry the mandatory labelling set by the food supplements directive.

How Commicorn helps

• A note when it matters. When your product is a supplement, the listing steps show a one-line note with Read more, which opens this page.
• Your label, as printed. Choose Untouched product for every image that shows the label. Your photo's pixels are never redrawn on that route, so the Supplement Facts panel stays exactly as printed.
• Keywords checked against the bans. The keyword step keeps out a keyword Amazon bars on a supplement listing, such as one that names a disease, and says why.
• Your claims, from your details. The listing copy is written from the details you give us. Read every line against your label before you export, and add the FDA statement wherever a structure/function claim appears.

Questions sellers ask

What is a structure/function claim?

A claim that describes how an ingredient affects the body's normal working, such as "supports restful sleep" or "helps maintain healthy joints". It is allowed with the FDA statement beside it.

What is the FDA statement for supplements?

The statement that must go with every structure/function claim, word for word: "This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease."

Can a supplement listing say it treats a disease?

No. A claim that a supplement treats, cures, mitigates or prevents a disease makes it an unapproved drug under US law, and Walmart and Amazon bar disease words in titles, bullets, images and search terms.

Can I use AI-generated label images for supplements on Amazon?

No. As relayed by a labelling firm that read Amazon's help page, supplement listing images must show the full label and must not be computer-drawn or AI-generated, enforced from 31 March 2026.

Does a supplement need a number to be sold in Canada?

Yes. Canada treats supplements as natural health products, and each needs a Natural Product Number on the label before it is sold.

Before you list

Have a straight, readable photo of the full label with the complete Supplement Facts panel, the FDA statement word for word beside every structure/function claim and, for Amazon.ca, the Natural Product Number on the label before the listing goes live. On a borderline claim, 21 CFR 101.93 settles it: a claim about the body's normal working is allowed with the statement, a claim about a disease is not. Whether you can list at all on Walmart is settled by its vetting for supplement sellers.