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Food supplements

Food supplements: what applies, what a passport must carry and when

Scope. Ordinary food supplements marketed as food, which sit outside the ESPR. A product presented or functioning as a medicinal product is a different classification question.

Do food supplements need a Digital Product Passport?

No generic ESPR Digital Product Passport applies to an ordinary food supplement marketed as food. Food is outside the scope of the Ecodesign for Sustainable Products Regulation and EU food-supplement law treats supplements as foodstuffs, so there is no passport obligation and no date to wait for.

That is worth saying precisely. This is a scope outcome, not a gap in the evidence: the instrument excludes food, so the answer is not applicable rather than not established. Nothing here is pending a delegated act, a study or a Working Plan entry, which is why the estate states no dated obligation for this category rather than because nobody has looked.

The real risk is classification. A commercial label is where a classification starts, not where it ends. EU medicinal-products law defines products by their presentation and by their function, so what the product contains, its dose and mode of action, how it is presented, the exact claims made and whether an electronic dispenser or app is a separate regulated product can all move a borderline case out of food law and into a regime that does have obligations.

2 pages here. Read the classification test before concluding that nothing applies to you.

Dates

The estate states no dated obligation for this category. That is not the same as none existing, and it is not a reason to wait: see every dated obligation the estate does state.

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