Food Supplement Labelling in Czechia: Legal Requirements and Inspection Risks

Mgr. Dita Zbožínková, LL.M.
Mgr. Dita Zbožínková, LL.M.
24.4.2026 | ARROWS law firm

Accurate labelling of a food supplement’s packaging is not merely an administrative formality that can be underestimated. The State Agricultural and Food Inspection Authority (SZPI) and other supervisory bodies, such as the Czech Trade Inspection Authority (ČOI), are carrying out increasingly intensive inspections to identify non-compliance in food supplements sold online. Breaching the requirements can cost you tens of millions of Czech crowns in fines or a sales ban, so it is essential to know exactly what the legislation requires.

The illustrative image shows a lawyer discussing the labelling of food supplements.

Quick summary

  • Notification is mandatory. Before placing a food supplement on the market in the Czech Republic for the first time, you must notify the product (submit the Czech label text). Failure to comply is an administrative offence and may result in a fine.
  • The packaging must contain mandatory information in Czech. The product name, the designation “food supplement”, the list of ingredients, highlighted allergens, recommended dosage, statutory warnings, and details of the food business operator.
  • Health claims must not be medicinal. You may use only authorised health claims from  or claims from the so-called on-hold list (for botanical substances). Medical and therapeutic claims lead to sales bans and high penalties.
  • Packaging intended for children is subject to strict rules. You must not use a presentation that could lead to confusion of a food supplement with ordinary confectionery, or graphics that encourage excessive consumption.

Legislative framework: What governs labelling

Labelling of food supplements in the Czech Republic is regulated by a complex set of Czech and EU regulations. The most important national implementing regulation is Decree No. 58/2018 Coll., on food supplements and the composition of foods, which sets specific requirements for composition and labelling. The umbrella act is Act No. 110/1997 Coll., on food and tobacco products. The formal requirements are governed by Regulation (EU) No 1169/2011 of the European Parliament and of the Council.

In the area of claims, the key instruments are Regulation (EC) No 1924/2006 on nutrition and health claims made on foods and Commission Regulation (EU) No 432/2012 establishing a list of permitted health claims.

It is important to note that food supplement legislation is not fully harmonised across the EU (especially regarding botanical ingredients and maximum limits for vitamins), which means that each Member State retains a certain degree of autonomy. In practice for the Czech Republic, this means that Czech requirements may differ in some respects from those in neighbouring countries.

Our attorneys in Prague at ARROWS advokátní kancelář deal with these issues on a daily basis and can explain to clients how to navigate the regulatory framework without the risk of mistakes. They know SZPI practice and understand what inspections most often focus on.

What must be included on a food supplement label without exception

The packaging of every food supplement placed on the Czech market must contain a range of mandatory information under Regulation No 1169/2011 and Decree No. 58/2018 Coll. Missing or inaccurate information may lead to sanctions.

Product name and the designation “food supplement”

The legal name of the product is the designation “food supplement”. This wording must appear on the packaging in a way that makes it clear to all consumers what category of product it is. If the packaging or presentation suggests that it is a medicinal product, an ordinary food, or a meal replacement, you are in breach of the law.

SZPI checks whether the designation “food supplement” is sufficiently visible and not hidden. In practice, this means it must be part of the main field of vision or in close proximity to the trade name.

List of ingredients and allergens

The packaging must include a list of ingredients in descending order by weight. This includes all active substances (vitamins, minerals, extracts) as well as additives (fillers, colourings, anti-caking agents).

  • Allergens: If the product contains allergens listed in Annex II to Regulation No 1169/2011, they must be emphasised in the list of ingredients (e.g., in bold or in a different font).
  • Clarity: Ingredients must be stated by their specific name. For example, instead of a chemical formula, you must state “Magnesium (magnesium citrate)” or “Vitamin C (L-ascorbic acid)”.
  • Additives: For additives, the category name is stated (e.g., “colour”) followed by the specific name or E number (e.g., “colour: caramel” or “colour: E150d”).

Importers from non-EU countries often make mistakes in translating the composition or in declaring substances that are considered additives in the EU and therefore must be labelled as such.

Recommended daily dosage

The packaging must state the recommended daily dosage (e.g., “1 capsule daily” or “5 g of powder daily”). This information is essential for calculating the amount of substances the consumer will ingest. The inspection checks whether the recommended dose leads to exceeding the maximum permitted limits for vitamins, minerals, or other substances set by legislation or by the risk assessment of the National Institute of Public Health (SZÚ).

Mandatory warnings and notices

Under Section 3 of Decree No. 58/2018 Coll., the packaging must contain the following standard notices:

  1. “Warning: Not intended as a substitute for a varied diet.”
  2. “Do not exceed the recommended daily dosage.”
  3. “Keep out of reach of children.”

These warnings are mandatory and their wording is prescribed (alternatively, wording with the same meaning may be used, but it is recommended to follow the decree). If the food supplement contains specific substances, additional warnings may be required.

Operator details

The packaging must state the name or business name and the address of the food business operator under whose name the food is marketed. If that operator is not established in the EU, the name and address of the importer to the EU market must be provided. It is not sufficient to provide only a website or email; it must be a physical address (registered office).

Amounts of vitamins, minerals and other substances

The packaging must include a table or list stating the amounts of biologically active substances (vitamins, minerals, extracts) per daily dose of the product.

  • For vitamins and minerals, the percentage of the reference intake value (RHP) must also be stated where applicable. In English, RHP is referred to as NRV (Nutrient Reference Value).
  • Declaration vs. reality: SZPI inspectors take samples for laboratory analysis. If they find that the actual content of substances differs significantly from the declared amount (taking into account permitted tolerances and measurement uncertainty), this constitutes misleading consumers.
Minimum durability date and storage conditions

A minimum durability date (MDD) must be stated in the format “Best before: [date]”. For food supplements, a “use by” date is generally not used unless the product is highly microbiologically perishable. Storage conditions must also be stated where necessary to maintain quality.

What SZPI focuses on when inspecting packaging

The State Agricultural and Food Inspection Authority (SZPI) carries out inspections based on its plan, consumer complaints, and online monitoring. It primarily focuses on:

  • Misleading or incomplete information – missing mandatory information in Czech, incorrectly labelled allergens, or a misleading product name.
  • Health and medicinal claims – the use of unauthorised claims or claims attributing to a food supplement properties of preventing, treating, or curing human diseases (which is strictly prohibited for foods under Section 5d(2) of the Food Act).
  • Notification – verification that the product has been duly notified (reported) to the Ministry of Agriculture.
  • Safety and prohibited substances – laboratory analyses for the presence of unauthorised substances (e.g., unauthorised forms of minerals, prohibited plants, doping-type substances, unauthorised “Novel Foods”).
  • Misleading presentation (Food Imitation) – whether the packaging or the form of the product may endanger consumers by being confused with ordinary food (e.g., confectionery) in a way that could lead to excessive consumption, especially by children.
Language, legibility and formal requirements

All mandatory information must be in the Czech language. Additional languages are permitted, but not at the expense of the legibility of the Czech text. Mandatory particulars must be clearly visible, legible and indelible. Regulation (EU) No 1169/2011 sets a minimum font size (the so-called x-height) of 1.2 mm.

The packaging must not contain misleading information within the meaning of the Czech Consumer Protection Act. This also includes graphic representations (e.g., an image of fruit that is not contained in the product, only its flavouring).

FAQ – Frequently asked questions on language and legibility

1. Can I provide information on the packaging in a foreign language if there is also a Czech version?
  Yes, multilingual packaging is common. However, the Czech information must be complete and identical in content to the foreign-language versions so as not to mislead consumers.

2. What happens if the packaging is not sufficiently legible?
  SZPI may order the product to be withdrawn from the market until the issue is remedied (re-labelling) and impose a fine for breach of the rules on the provision of information.

3. Do I have to have an “approved by SZPI” logo on the packaging?
  No. SZPI does not approve products; it only inspects them. Making such statements would be misleading and unlawful.

Health claims: What you may and may not claim

Legislation distinguishes between nutrition and health claims:

  • Nutrition claims (e.g., “source of vitamin C”, “sugar-free”) may be used if the product meets the conditions set out in the Annex to Regulation (EC) No 1924/2006.
  • Health claims (e.g., “Vitamin C contributes to the normal function of the immune system”) may be used only if they are authorised by the European Commission and listed in . You must follow the exact wording.
  • On-hold claims: For botanical substances (botanicals), the situation is specific. These claims are “on hold” and may be used on an interim basis provided they are scientifically substantiated and do not constitute medicinal claims.

You must never attribute to food supplements the ability to prevent, treat or cure human diseases, nor refer to such abilities. Words such as “treats”, “heals”, “against pain”, “inflammation” are risky in the context of food supplements and are often prohibited.

Packaging intended for children: Special rules and risks

If a food supplement is intended for children, stricter standards apply.

1. Unsuitability for children: If the product is not suitable for children (e.g., contains caffeine, certain herbs, or high doses of vitamins), this warning must be expressly stated on the packaging.

2. Resemblance to confectionery: Care must be taken to ensure that the form of the food supplement (e.g., gummy sweets) and its packaging do not lead to confusion with ordinary confectionery, which could result in unintentional overdose by a child.

3. Child-resistant closure: For products where there is a risk if children ingest larger quantities (e.g., iron), the use of a child-resistant closure is highly recommended.

Notification: A step you must not skip

Under Section 3d of Act No. 110/1997 Coll., every food business operator placing a food supplement on the market in the Czech Republic is required to notify the Ministry of Agriculture (MZe) of this fact before the first placing on the market.

  • Purpose: This is an information obligation (market monitoring). MZe does not approve the product; it only records it in the RoBal database. Full responsibility for composition and labelling lies with the operator.
  • Sanctions: Failure to comply with the notification obligation is an administrative offence for which a fine may be imposed.
  • Changes: If a material change occurs (composition, name, dosage), a new notification (re-notification) must be made.

Food supplement composition: Permitted and prohibited substances

The composition of food supplements is regulated by Decree No. 58/2018 Coll. and directly applicable EU regulations.

  • Vitamins and minerals: Only substances listed in Annex II to Directive 2002/46/EC (or Decree No. 58/2018 Coll.) and in the chemical forms specified there may be used.
  • Plants and other substances: Some plants are prohibited or restricted (e.g., in the Annex to Decree No. 58/2018 Coll.).
  • Novel Foods: Substances that were not consumed to a significant degree in the EU before 15 May 1997 must undergo the EU authorisation process as . If they are not authorised, they must not be used.
  • Contaminants: The product must comply with limits for heavy metals, pesticides, PAHs and other contaminants under .

Lawyers from ARROWS advokátní kanceláře regularly handle cases involving product withdrawals due to the presence of unauthorised substances, such as ethylene oxide or unauthorised extracts.

Risk table: What you face in the event of a breach

Risks and sanctions

How ARROWS can help (office@arws.cz)

Misleading consumers / Safety: Fine of up to CZK 50 million (under Section 17f of the Food Act), sales ban, order to withdraw from the market.

Packaging audit and review

Use of medicinal claims: Fine, advertising ban, penalties imposed by the Czech Trade Inspection Authority (ČOI) and the State Agricultural and Food Inspection Authority (SZPI).

Claims consultation

Breach of the notification obligation: Financial penalty for an administrative offence, record of the breach with supervisory authorities.

Handling the notification

Presence of prohibited substances (e.g., Novel Food): Immediate sales ban, product recall from customers, fine.

Compliance check

Misleading presentation (Food Imitation): Withdrawal of the product due to the risk of confusion and endangering health.

Design assessment

Specific warnings for sensitive groups

Decree No. 58/2018 Coll. and other regulations set out specific warnings. For supplements with a vitamin A content higher than 800 µg in the daily dose, a warning for pregnant women must be stated. For St John’s wort (Hypericum perforatum), it is necessary to warn about a possible reduction in the effect of medicines.

If the product contains a high amount of caffeine, it is necessary to include the warning “Not suitable for children and pregnant or breastfeeding women” together with the information on the amount of caffeine. The absence of these warnings may be assessed as placing unsafe food on the market.

Laboratory analysis and evidence

The operator must be able to demonstrate that the information on the packaging corresponds to reality. The key document is a laboratory analysis (Certificate of Analysis) from an accredited laboratory.

When importing from third countries, it is essential to verify each batch or have a robust supplier control system, because the importer into the EU bears responsibility for compliance. SZPI inspectors routinely take their own samples; if their results differ from your declaration, the burden of proof and the costs of the proceedings are on you.

Advertising and sales channels: online and offline

Labelling rules also apply to presentation and advertising, i.e., websites, e-shops and social media. Information provided online before purchase must (with the exception of the date of minimum durability) correspond to the mandatory particulars on the packaging.

Misleading advertising, such as fictitious reviews or false claims about effects, is sanctioned under the Consumer Protection Act, with fines that may also reach millions of Czech crowns. Attorneys from ARROWS, a Prague-based law firm, provide audits of e-shops and marketing campaigns to ensure they comply with Czech law.

Criminal liability

In serious cases where there is intentional endangerment of consumers’ health (e.g., by adding toxic substances, knowingly selling spoiled goods, or dangerous “counterfeits”), the conduct may constitute the criminal offence of endangering health with defective food and other items (Section 156 of the Criminal Code). Penalties may include imprisonment, a ban on activity, or a financial penalty.

Conclusion

Labelling of food supplements is a complex discipline combining food law, consumer protection and administrative procedure. An error in label wording or failure to submit a notification may lead to crippling fines and loss of trust. Attorneys from ARROWS, a Prague-based law firm, have extensive experience in this area and will help you set up processes to minimise risks.

If you want to be confident that your product and its packaging will withstand an SZPI inspection, contact us at office@arws.cz.

FAQ – Most common legal questions on labelling food supplements

1. What if we change the composition or dosage of a food supplement – do I have to notify again?
Yes. A material change to the product requires a new notification to the Ministry of Agriculture, including the current label text.

2. Can I use English names of ingredients instead of Czech ones?
No, mandatory information (including ingredient names in the list of ingredients) must be in the Czech language. Latin plant names may be provided additionally.

3. What happens if the inspection finds a lower vitamin content than I declare?
It may constitute misleading consumers. SZPI takes into account natural deviations and measurement uncertainty, but if the difference is outside the tolerance, a fine and an order to remedy may follow.

4. What is the difference between DMT and DUP?
DMT (date of minimum durability) is used for durable foods, including most food supplements (“best before”). DUP (use-by date, “use by”) is used for foods that spoil quickly, which is not common for food supplements.

5. Can I write “scientifically proven” on the packaging?
Only if you have generally recognised scientific evidence relating to your product or its ingredients and the claim complies with Regulation No. 1924/2006. Without evidence, it is a misleading commercial practice.

6. How long does it take for the inspection to investigate a complaint?
Time limits vary depending on the authority’s workload and the complexity of the case; however, the inspection must act in accordance with the Administrative Procedure Code. If you are facing an inspection, we recommend legal representation from the outset of the proceedings.

Notice: The information contained in this article is of a general informational nature only and is intended to provide basic guidance based on the legal status as of 2026. Although we take the utmost care to ensure accuracy, legal regulations and their interpretation evolve over time. We are ARROWS advokátní kancelář, an entity registered with the Czech Bar Association (our supervisory authority), and for maximum client protection we maintain professional liability insurance with a limit of CZK 400,000,000. To verify the current wording of regulations and their application to your specific situation, it is necessary to contact ARROWS advokátní kancelář directly (office@arws.cz). We accept no liability for any damages arising from the independent use of the information in this article without prior individual legal consultation.

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