In the UK, products that sit between food supplements and medicines are often referred to as “borderline products.” These are items that may appear to be food supplements based on their format or ingredients, but whose presentation or claims could cause them to be classified as medicinal.


Understanding borderline classification is important for any brand selling supplements. A product does not need to contain pharmaceutical ingredients to fall into this category. In many cases, wording and marketing positioning are the determining factors.


Who Decides If a Product Is Borderline?

The Medicines and Healthcare products Regulatory Agency (MHRA) is responsible for determining whether a product should be regulated as a medicine in the UK. Classification is made on a case-by-case basis. There is no single checklist that guarantees a product will remain within food law. Instead, regulators assess:

  • The product’s name

  • Label wording

  • Claims made on packaging

  • Website and advertising content

  • Overall presentation

  • Consumer perception

Even if a product is sold in capsule or tablet form and contains common supplement ingredients, it may still be assessed as medicinal depending on how it is described.


Why “Borderline” Does Not Mean Illegal

It is important to understand that a borderline product is not automatically non-compliant. The term simply means that the product could fall under either food or medicines legislation depending on its presentation. Many supplements remain fully compliant because:

  • They avoid disease treatment claims

  • They use authorised health claims where applicable

  • Their marketing focuses on supporting normal physiological function

Problems typically arise when positioning moves beyond general health support into implied therapeutic use.


Common Triggers for Borderline Classification

Certain themes increase risk of medicinal classification.


1. Disease Language

Statements that suggest treatment, prevention, or cure of a disease are high risk. Examples include references to:

  • Anxiety disorders

  • Depression

  • Arthritis

  • Insomnia

  • Hormonal disorders

  • Chronic inflammation

Even indirect phrasing can create issues.


2. Implied Therapeutic Positioning

Sometimes the wording does not explicitly mention a disease but strongly implies one. For example:

  • “For menopause treatment”

  • “For ADHD support”

  • “Natural alternative to prescription pain relief”

These statements move beyond general health support.


3. Dosage & Strength Emphasis

Very high-strength positioning combined with therapeutic claims may increase scrutiny, particularly if the product is presented as offering medical-level results. Strength alone does not determine classification, but context matters.


4. Marketing Beyond the Label

Regulators consider the full marketing environment. This includes:

  • Website copy

  • Blogs

  • Marketplace listings

  • Social media content

  • Influencer scripts

  • Customer testimonials displayed on your site

A compliant label can still be undermined by non-compliant marketing content elsewhere.


How Borderline Decisions Are Made

There is no automatic formula. Each case is assessed individually. Regulators look at:

  • Overall consumer impression

  • The balance of wording

  • Whether the average consumer would view the product as medicinal

Because the assessment considers perception, even subtle wording choices can influence classification.


Practical Risk Management for Brands

To reduce borderline risk:

  • Avoid referencing named diseases

  • Use authorised UK health claims where available

  • Keep marketing focused on supporting normal bodily functions

  • Monitor affiliate and influencer messaging

  • Review website FAQs and blog content regularly

Clarity and restraint in wording are often the most effective safeguards.


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.