Rocket Fuel vs. a proprietary-blend tablet: the two labels, line by line

Two Supplement Facts panels, one set of rules. Rocket Fuel's panel lists one dietary ingredient with one amount. A proprietary-blend panel lists a group of ingredients under one name with one combined weight. Both formats come from the same regulation, 21 CFR 101.36. What differs is what each line tells you, and what you can calculate from it. One label below is real, the Rocket Fuel box, quoted as printed. The other is invented.

The two panels side by side

Line 1: the ingredient name

Dietary ingredients with no Daily Value "shall be declared by their common or usual name" (21 CFR 101.36(b)(3)(i)). On the Rocket Fuel panel that line reads Natural Oyster Extract Powder. Four words, one ingredient, and the name is the whole description: the panel prints no extract ratio and no species, so those are not stated.

A blend gets a name of its own first: "Proprietary Blend" or an "appropriately descriptive term or fanciful name" (101.36(c)). The ingredients inside keep their common or usual names, "indented under the term 'Proprietary Blend'" and "declared in descending order of predominance by weight" (101.36(c)(2)). So "Vitality Blend" is a name, not information; the four indented names below it are the information.

Lines 2 and 3: the amount and the Daily Value column

For a single ingredient the rule is direct: "The quantitative amount by weight shall be the weight of the other dietary ingredient listed" (101.36(b)(3)(ii)), in metric units. Rocket Fuel prints 300 mg next to its one ingredient, the weight per 1-tablet serving.

For a blend, the number on the name line is a sum: "the total weight of all other dietary ingredients contained in the proprietary blend" (101.36(c)(3)). FDA's labeling guide, question 34, agrees: "On the same line, you must list the total weight of all 'other dietary ingredients' contained in the blend." Dietary ingredients that have a Daily Value "must be listed separately and the individual weights declared."

Notice what is missing. The regulation names the total weight and the order; a per-ingredient amount is not among the items it lists. On the invented label, 500 mg is four ingredients added together, and the weight of any one of them is not stated.

The Daily Value column looks the same on both labels. An ingredient with no Daily Value "shall bear a symbol (e.g., an asterisk)" pointing to a footnote "followed by the statement 'Daily Value not established'" (101.36(b)(3)(iv)); a blend's total gets the same symbol (101.36(c)(3)). FDA's guide defines "other dietary ingredients" as those "that do not have Daily Values (i.e. RDIs or DRVs)" (question 28), a group that includes oyster extract powder and the four ingredients of our invented blend. The footnote says the ingredient has no Daily Value, nothing more.

Line 4: other ingredients, below the panel

Non-dietary ingredients go outside the panel. The list "shall be located immediately below the nutrition label" (21 CFR 101.4(g)) and, when the sources already appear inside the panel, is "preceded by the words 'Other ingredients'" (101.4(g)). Names run "in descending order of predominance by weight" (101.4(a)(1)); a percentage is shown in parentheses only "if the percentage of an ingredient is included" (101.4(e)), so amounts on this line are optional.

Rocket Fuel's line is xylitol and starch: two names, no amounts, and the rule asks for none. The invented capsule prints capsule shell and rice flour. Here the two formats match; the difference lives inside the panel.

Serving size, directions and warnings

"Serving Size" sits under the title (101.36(b)(1)(i)) in "a term that is appropriate for the form of the supplement": tablet or capsule. FDA's guide, question 4: "One serving of a dietary supplement equals the maximum amount recommended, as appropriate, on the label for consumption per eating occasion," or 1 unit when the label makes no recommendation.

Rocket Fuel's serving size is 1 tablet; the directions read 1 tablet every 3 days; each pack holds 2 tablets. The product page also prints "Contains oyster (shellfish). Do not take if allergic. Not intended for anyone under 18." Directions and warnings are the manufacturer's own lines, outside the 101.36 panel; none of the three sources read for this post covers their wording, so we quote them and stop.

What each label lets you calculate

With one ingredient and one amount, every number on the Rocket Fuel label turns into a per-tablet or per-milligram figure by plain division, and days covered follow from 1 tablet every 3 days. Prices are from the product page at the time of writing.

Our own label Rocket Fuel From $14.95 See the label

Now try the invented label. Say the box costs $30.00 for 30 servings: $1.00 per serving, and $30.00 divided by 15,000 mg of blend is $0.002 per milligram of blend. Price per milligram of Ingredient A: not computable, because the label gives no weight for Ingredient A. The total and the order are real, but the per-ingredient figure a comparison needs is not on the label.

A declaration, not an approval

Both panels are legal; the regulation describes both formats in one section and permits either. Dietary supplements don't require FDA approval before sale, and the Supplement Facts panel is the manufacturer's own declaration of what is in the box, in the format 21 CFR 101.36 prescribes. Read line by line, the two formats differ in one thing: a number per ingredient, or a number per blend. If the question is personal, take it to a doctor or pharmacist, with the box in hand.