FDA food + structure-function claims compliance, what can you actually say?

The FDA distinguishes three claim types and the line between them is the #1 legal risk for vegan + plant-based brands:

• Nutrient content claims, “high in protein,” “good source of fiber.” Strictly defined by FDA thresholds. Lab-test the SKU, hit the threshold, you can use the claim.
• Structure-function claims, “supports immune function,” “promotes digestive health.” Allowed without pre-approval but must be truthful, not misleading, and not imply disease treatment. Requires a disclaimer (“This statement has not been evaluated by the FDA…”).
• Disease claims, “lowers cholesterol,” “prevents heart disease,” “cures….” Banned without FDA pre-approval (very rare). Marketing copy that crosses this line gets warning letters and product seizures.

Vegan-specific traps:

• “Heart-healthy”, only allowed if SKU meets specific saturated-fat + cholesterol thresholds.
• “Boosts immunity”, structure-function. Needs disclaimer. Don’t imply disease prevention.
• “Anti-inflammatory”, drifts toward disease claim. Risky without published literature on the specific ingredient.
• “Detox / cleanse”, FDA + FTC actively police this. Avoid entirely.

On Magento, every claim should be auditable: store the claim text + its evidence (lab test, peer-reviewed citation, or disclaimer) as a product attribute, and have legal sign-off captured before the SKU goes live. The PDP description + meta description + structured data all need the same disclaimers if used. Don’t inherit claim language from competitors, their lawyers may have signed off, yours haven’t.