DR. SARAFI Rechtsanwaltsgesellschaft mbHFrankfurt am Main · Throughout Germany

Legal advice for supplement brands, manufacturers & retailers

Food supplements.

Before your labels and advertising go to print.

You develop a food supplement. We review how you label and advertise it: from the product name, nutrient information and health claims to your online shop and creator brief. DR. SARAFI Rechtsanwälte brings together food law, unfair competition law and the contracts behind your brand.

Request a product review

Food supplements

What we review for your brand.

A draft label, a new formulation or an entire product launch: we agree on a specific scope of review. You receive a legal assessment of the agreed documents, recommendations for changes and an overview of any evidence still needed. We identify any scientific assessments required as separate work.

01

Labels, daily servings & NRVs

The ingredients list, recommended intake, mandatory warnings and stated quantities must be appropriate for your product. We review the labelling and nutrient reference values against your specifications, distinguishing mandatory declarations from advertising statements such as “with vitamin C”. Legibility and the presentation in your online shop are also included in the agreed scope of review.

Review labelling and mandatory information
02

Health claims & product names

A claim about a product’s effects may appear in a slogan, a product name or an image. We review the message conveyed, the relevant conditions of use and any supporting information required. We consider general health references and claims about botanical substances separately. An authorised claim is not automatically suitable for every formulation.

Rules for health claims
03

Botanical substances, extracts & novel foods

The plant species, plant part used, manufacturing process and extract specification can be decisive for the legal assessment. We identify any documents still needed for the review and whether a novel food issue arises. The fact that a plant is well known does not establish whether every extract made from it may lawfully be used.

Discuss your product and specifications
04

Online shops, advertising & creator campaigns

Our review extends beyond the container. We include product pages, advertisements, videos and specific creator briefs. Through consistent claims, documented approvals and suitable collaboration agreements, we help your team align product documentation with the advertising actually published.

Align advertising and creator contracts
05

UWG, cease-and-desist notices & objections

Incorrect mandatory information or unlawful claims about a product’s effects can also have consequences under unfair competition law. We review cease-and-desist notices, demands to stop particular conduct and regulatory objections. We also assess action against specific unfair advertising by competitors. The legal basis of a claim, standing to bring it and further steps are assessed in each case.

Review unfair competition risks and claims
06

Trade marks, contract manufacturing & distribution

Who supplies which specifications? Who coordinates label approval? How are formulation changes and objections handled? We draft contracts with manufacturers, suppliers and distribution partners, taking trade mark protection into account. Registering a trade mark does not, however, replace a food law review of the product name.

Define responsibilities in your contracts

Specific enquiries

Is this the right service for you?

Manufacturers, supplement brands and food supplement retailers

Our label is going to print. Are the NRVs, mandatory information and advertising claims correct?

We review the agreed drafts against the formulation and specifications and identify changes needed from a legal perspective. The complete packaging, daily serving, target group and corresponding online shop page are helpful. We agree on the scope and fees before work begins.

Request a label review before printing

A competitor is challenging our product name or a claim about its effects.

We review the complete cease-and-desist notice, the specific advertising and the product documents. We distinguish between labelling, health claims and claims under unfair competition law. Include any existing deadlines in your enquiry.

Review a cease-and-desist notice about supplement advertising

To prepare

That helps us
understand your matter.

First, briefly describe your concern. We will coordinate the submission of further documents with you.

  • Current formulation, daily serving and target group for the product
  • Specifications and analyses; for botanical substances, also the plant species, plant part and extract data
  • Complete draft label and packaging, including the product name and images
  • Online shop copy, advertisements, claims and planned creator briefs
  • Target markets, sales channels and existing manufacturing or distribution contracts
  • If an objection has been raised: the complete letter, attachments, deadlines and previous correspondence

That's how we work together.

We agree on the assignment, the legal contact and the remuneration before processing.

01

Inquiry

They describe the facts, the parties involved and known deadlines.

02

Acceptance of your matter

We agree on performance and compensation and name your contact person.

03

Case handling

The responsible lawyer will check your documents and coordinate the procedure with you.

Good to know

your questions.

What do I receive from a label and advertising review?

We first agree which products, markets and versions will be reviewed. Within the agreed scope, you receive a legal assessment, specific guidance on statements requiring changes and, where possible, suggestions for revisions. Missing specifications or scientific evidence are identified as outstanding points. A legal review does not replace laboratory analysis or any required safety assessment. We agree on the services and fees before work begins.

Is the NRV a prescribed daily intake?

No. NRV stands for nutrient reference value. It is a benchmark for the labelling of vitamins and minerals, not an individual intake recommendation. For food supplements, the stated quantities relate to the recommended daily intake. Whether a nutrition claim used in advertising is permitted must be assessed separately. The NRV does not establish a blanket minimum quantity for every food supplement.

Can a product name itself be a health claim?

Yes. A trade mark, brand name or invented name may also be understood as a nutrition or health claim. What matters is how it is perceived in the context of the product’s presentation and advertising. We therefore review names, images and accompanying text as well as explicit claims about a product’s effects. Registering a trade mark does not resolve this question.

What does the Botanicals judgment mean for advertising botanical substances?

In Case C-386/23 on 30 April 2025, the Court of Justice of the European Union (CJEU) explained the limits on claims concerning psychological or behavioural functions that have not yet been authorised, and on general health references. A pending assessment is not a blanket permission to advertise; the requirements of any transitional provision remain decisive. On 5 June 2025, the German Federal Court of Justice (BGH) applied this ruling in the underlying proceedings, I ZR 109/22 (“Botanicals II”). This does not establish a general ban on selling botanical substances. For your product, we assess the specific substance, claim and applicable requirements.

How does food law relate to the UWG?

Rules on labelling and advertising may also regulate market conduct. A breach may therefore constitute unfair competition under the conditions of section 3a of the German Act Against Unfair Competition (UWG); misleading statements may fall within section 5 UWG. Parties with standing may, in particular, seek an injunction or removal of the infringement. Not every inconsistency automatically gives rise to a claim. We assess the specific statement, its significance and the requirements for a claim.

Is notification to the BVL enough to start selling?

No. The mandatory notification of a food supplement to Germany’s Federal Office of Consumer Protection and Food Safety (BVL) is not a product authorisation. According to its official guidance, the BVL does not assess whether a product may lawfully be placed on the market as part of the notification procedure. Composition, labelling and advertising therefore require their own assessment.

Can you also support our ongoing product development?

Yes. As well as reviewing an individual label, we can support an agreed process for new products, formulation changes and advertising materials. This involves defining responsibilities, the documents to be reviewed and approval steps. A review of a particular version is not a blanket approval for later changes or all advertising.

DR. SARAFI Rechtsanwälte

Your concern: Dietary supplements

Briefly describe your case and known deadlines. We clarify the takeover, the scope of services and the remuneration.

Get in touchBook a consultationinfo@sarafi.deAn engagement begins only when we expressly accept it.

English translation of our German website. Statutory references concern German or EU law. The German original remains available through the language selector.