In the UK, food supplements and medicines are regulated under different legal frameworks. Most supplements are sold lawfully as foods. However, a product can be considered “medicinal” depending on how it is presented, described, or marketed - even if the ingredients themselves are commonly used in supplements.


Understanding this distinction is important for brand owners, particularly when creating label copy, website content, and marketing materials.


The Two Key Tests Used by the MHRA

The Medicines and Healthcare products Regulatory Agency (MHRA) uses two main tests when assessing whether a product is medicinal:


1. The Presentation Test

If a product is presented as preventing, treating, or curing a disease, it is likely to be considered a medicine. This assessment is based on:

  • Label wording
  • Website descriptions
  • Social media content
  • Testimonials
  • Influencer marketing
  • Product name
  • Packaging imagery

Even implied claims can trigger this test.


2. The Function Test

If a product has a pharmacological, immunological, or metabolic action with the intention of restoring, correcting, or modifying physiological functions in a way typical of medicines, it may also fall under medicinal classification. This is assessed case-by-case and considers both dosage and context.


Examples of High-Risk Wording

Certain types of claims are consistently problematic.

  • “Treats anxiety”
  • “Prevents arthritis”
  • “Cures insomnia”
  • “Reduces inflammation in joints”
  • “Balances hormones for menopause treatment”
  • “Natural antidepressant”

These phrases suggest treatment or prevention of disease.


Compliant Alternatives

  • “Magnesium contributes to normal psychological function.”
  • “Vitamin D contributes to the maintenance of normal bones.”
  • “Supports normal immune function.”

Permitted claims must align with authorised UK health claims.


Why Ingredients Alone Do Not Determine Status

A common misconception is that if an ingredient is allowed in food supplements, any claim about it is acceptable. This is not correct.

An ingredient may be lawful to sell as a supplement, but:

  • The way it is described can trigger medicinal classification
  • The dosage positioning may raise questions
  • The surrounding marketing context may change interpretation

The assessment is based on the overall presentation, not just the ingredient list.


Online Marketing and Marketplace Risk

Borderline risk does not stop at the label. Product listings on:

  • Amazon
  • TikTok Shop
  • Shopify websites
  • Blog posts
  • Email campaigns

are all considered part of how a product is presented. 


Customer testimonials hosted on your website may also be considered part of product presentation.

For example:

“This cured my insomnia.”

If displayed on your product page, this may be interpreted as a medicinal claim.


What Happens If a Product Is Considered Medicinal?

If the MHRA determines that a product is medicinal:

  • It cannot legally be sold as a food supplement
  • It would require a marketing authorisation as a medicine
  • Listings may be removed
  • Trading Standards may become involved
  • Insurance and liability risks may increase

Most cases are resolved by correcting claims and presentation rather than reformulating the product.


How to Reduce Borderline Risk

Brand owners should:

  • Avoid disease-treatment language
  • Use authorised UK health claims where applicable
  • Avoid “clinically proven to treat” statements
  • Monitor influencer and affiliate marketing content
  • Review website FAQs and blog articles
  • Ensure testimonials are moderated appropriately

If in doubt, simplify the wording.


Nutribl’s Approach

Nutribl operates within a BRC-certified supply framework and supplies private label stock supplements intended for sale under UK food supplement regulations.


We can provide advisory label text files based on our interpretation of applicable UK labelling and claims legislation. These are provided for guidance only. Brand owners are fully responsible for:

  • Final label wording

  • Website content

  • Marketplace listings

  • Marketing materials

  • Influencer and affiliate messaging

All label artwork must be reviewed and formally signed off by the client before production. Because regulatory interpretation can evolve and classification decisions are made case-by-case by authorities, it is the responsibility of each brand owner to ensure their final presentation remains compliant.


Clear and cautious positioning helps reduce regulatory risk and protects long-term brand stability.