Short answer
In Poland, as across the EU, a supplement may only carry health claims authorised under Regulation (EC) No 1924/2006 and listed in the EU Register, used for the right ingredient, at a dose that meets the conditions of use, and in wording that keeps the same meaning. This applies to labels, websites, ads and influencer content alike.
Health claims for supplements: the EU framework that applies in Poland
Health claims for supplements in Poland are governed by EU law, not by a separate Polish list. The core act is Regulation (EC) No 1924/2006 on nutrition and health claims made on foods. It applies directly in every member state, so the rules are the same in Warsaw and in Munich. What differs is enforcement practice, the attention of local authorities and the habits of the local market.
Three definitions matter:
- A claim is any message or representation, including pictures, graphics and symbols, that states, suggests or implies that a food has particular characteristics.
- A health claim states, suggests or implies a relationship between a food or ingredient and health - for example that calcium is needed for normal bones.
- A nutrition claim states or implies that a food has particular nutritional properties - for example “source of vitamin D” or “high in fibre”.
The key principle is a positive list. If a claim is not authorised, it is not allowed. There is no “it is scientifically true, so we can say it” route for commercial communication.
The EU Register: authorised, rejected and on hold
The European Commission keeps the EU Register of nutrition and health claims. For supplements, the most relevant part is the list of authorised general function claims (Article 13(1)), adopted mainly through Regulation (EU) No 432/2012 and later amendments. The register also contains claims on reduction of disease risk and on children's development (Article 14), and it records claims that were rejected.
Botanicals are the difficult part. A large group of claims for plant substances was put “on hold” while the Commission considered how to assess them. They are neither authorised nor rejected. Under the transitional provisions of the regulation, on-hold claims may in principle continue to be used under the conditions of those transitional rules and national provisions, at the operator's own responsibility.
What that means in practice in Poland:
- On-hold does not mean approved. There is no EU-level scientific endorsement behind the wording.
- The burden sits with you. If an authority challenges the claim, you need to show it is used within the transitional framework and is not misleading.
- Conservative wording wins. Many Polish brands use on-hold botanical claims, but in cautious, factual language and never as the only reason to buy.
Because this area is genuinely unsettled, we always ask a food law firm to confirm botanical claims before the label goes to GIS.
Conditions of use and wording flexibility
Every authorised claim comes with conditions of use. For vitamins and minerals, the typical condition is that the product contains at least a significant amount of the nutrient, as defined in the Annex to Regulation (EU) No 1169/2011 and expressed against the nutrient reference value. Other substances have their own conditions: a minimum daily intake, a specific form, or a required statement for the consumer.
Wording can be adapted, but only so far. The accepted test across the EU is that the reworded claim must have the same meaning for the consumer as the authorised one. Member states have issued guidance, and the general direction is consistent:
- Allowed: natural rephrasing, such as “vitamin C helps your immune system to function normally”.
- Not allowed: strengthening, such as “boosts”, “supercharges” or “protects against infections”.
- Not allowed: moving the claim to another ingredient, or implying the whole product has the effect when only one ingredient does.
- Not allowed: claims about preventing, treating or curing disease, which are prohibited for foods under Regulation (EU) No 1169/2011.
General, non-specific references to health, such as “for your wellbeing”, are only allowed when accompanied by a specific authorised claim (Article 10(3) of Regulation 1924/2006).
Non-compliant vs compliant phrasing
The table uses general examples. The compliant wording follows authorised claims in the EU Register; always check the exact entry and conditions for your ingredient and dose.
| Typical non-compliant phrasing | Why it fails | Compliant direction |
|---|---|---|
| “Boosts immunity” | Strengthens the meaning; implies effect beyond normal function | “Vitamin C contributes to the normal function of the immune system” |
| “Protects you from colds and flu” | Disease prevention claim, prohibited for food | Use the authorised immune function claim for a qualifying ingredient |
| “Clinically proven to reduce fatigue” | Adds a claim of proof and intensity not in the register | “Magnesium contributes to the reduction of tiredness and fatigue” |
| “Strong bones for life” | Vague promise, no ingredient, no authorised wording | “Vitamin D contributes to the maintenance of normal bones” |
| “Detox formula” | Implies a health effect with no authorised claim | Remove, or replace with an authorised claim for a named ingredient |
| “Supports hormonal balance” (product level) | Attributed to the whole product, not a specific ingredient | “Vitamin B6 contributes to the regulation of hormonal activity” |
| “Rich in vitamin D” at a trace dose | Nutrition claim threshold not met | Meet the Annex threshold or drop the claim |
Nutrition claims vs health claims
Brands often treat these as one thing. They are two lists with different logic, and a supplement label usually needs both.
| Aspect | Nutrition claim | Health claim |
|---|---|---|
| What it says | How much of a nutrient the product contains | What a nutrient or ingredient does for the body |
| Legal source | Annex to Regulation (EC) No 1924/2006 | EU Register, mainly Regulation (EU) No 432/2012 and amendments |
| Typical example | “Source of vitamin D”, “high in vitamin C” | “Vitamin D contributes to the maintenance of normal bones” |
| Main condition | A quantitative threshold per portion or per 100 g | A qualifying dose, and often a specific form or target group |
| Typical mistake | Claiming “high in” at a dose that only qualifies as “source of” | Rewording the claim into something stronger |
Two practical points. First, the dose that qualifies an ingredient for a health claim is usually tied to the same significant amount that underpins the nutrition claim, so check them together. Second, comparative claims such as “50% more vitamin D” have their own rules: the comparison must be with a range of foods of the same category and the difference must be stated. For most supplement brands, the safer route is to drop comparative copy entirely and let the dose table speak.
A final point that surprises US brands: “sugar free”, “vegan” and “natural” are not all treated the same way. Some are nutrition claims with conditions, others fall under general rules on misleading information. Check each one rather than assuming.
Claims in advertising and influencer content in Poland
Regulation 1924/2006 covers commercial communication in any form, not just the label. In Poland that includes product pages, marketplace listings, paid social ads, newsletters, and content produced by creators you pay or supply with product.
Three Polish realities to plan for:
- Sanitary inspection looks at labels and online presentation of supplements, and can act on claims used in marketing.
- The consumer protection authority (UOKiK) has been active on influencer marketing and on how commercial content is disclosed. Undisclosed paid content is a separate risk on top of the claim itself.
- Supplement advertising is a political topic in Poland. Stricter rules on supplement advertising have been discussed for years. Build your communication so it survives tighter rules, rather than relying on the current grey areas.
For creators, write a short claims brief: the authorised claims they may use, the exact wording, the words they must not use and the disclosure format. Creators will paraphrase. Your brief decides whether the paraphrase stays legal. More on channels in our guide to selling supplements on Allegro.
A claims review process that works
- List every claim you use today - label, website, marketplace listings, ads, creator briefs. Include images and icons.
- Map each claim to a register entry and a specific ingredient. No entry means rewrite or remove.
- Check conditions of use against your actual dose per daily portion and the NRV thresholds.
- Mark botanical on-hold claims separately and have them reviewed by a food law firm.
- Write a Polish claims library - approved sentences your team and creators can copy.
- Review again before every relaunch, new flavour or reformulation.
Claims also shape the GIS notification, because the label you submit carries them. If you want your claims mapped against the register and against what competitors in your category actually say on their Polish labels, start with our market entry report.