EU Health Claims (Regulation 1924/2006): a 2026 launch checklist

Why claims decide your launch

Regulation (EC) No 1924/2006 governs every nutrition and health claim made on food and food supplements sold in the EU. A claim is any statement that says or implies a product has beneficial properties — "supports immunity", "high in fibre", "contributes to normal energy metabolism". If a claim is not authorised, it cannot be used, regardless of how true it feels.

For a brand entering DACH, France, Italy or the Netherlands, the practical consequence is simple: your claim strategy gates your recipe. The authorised wording dictates the nutrient, the minimum dose per serving and the on-pack conditions of use.

The three claim families

Nutrition claims

Statements like "source of protein", "high fibre" or "low sugar". Conditions are fixed in the Annex to 1924/2006 — e.g. "source of protein" requires at least 12% of energy from protein. These are the fastest to use because the thresholds are already defined.

Health claims — Article 13.1

General function claims backed by generally accepted science, already assessed by EFSA and published in the EU Register. Example: "Vitamin C contributes to normal functioning of the immune system." Use the authorised wording and meet the significant-amount threshold (typically 15% NRV per portion).

Health claims — Articles 13.5 and 14

New function claims based on newly developed evidence (13.5), and disease-risk-reduction or children's-development claims (14). These require a dossier and an EFSA opinion before authorisation — months to years. Do not build a launch timeline that assumes a positive opinion.

The 2026 launch checklist

1. List every benefit message marketing wants to make.
2. Map each to the EU Register: authorised, on-hold, or not listed.
3. Drop or rephrase anything not authorised; replace implied disease claims with permitted function claims.
4. Lock the nutrient and dose so the product actually qualifies for the claim.
5. Verify the on-pack conditions of use (warnings, "consume as part of a varied diet").
6. Translate claims using the authorised wording in each target language — the Register is multilingual.

The botanicals trap

Hundreds of "herbal" / botanical health claims remain on hold pending EFSA assessment. Many supplement launches lean on exactly these. A compliant 2026 strategy keeps botanical messaging within general descriptive bounds and never states a specific health effect that is not authorised.