What structure-function claims can brands make with collagen peptides?

Beyond Biopharma | Collagen Peptide FAQ

Short answer: Collagen peptides can support structure-function style statements, which describe how an ingredient affects the normal structure or function of the body, for example supporting skin, joint or bone health. They cannot support claims to treat, cure, prevent or diagnose a disease. The exact wording allowed, and the disclaimers that must accompany it, differ between markets, so every claim should be checked against the rules of the country where the product is sold.

The distinction that decides everything

Food and supplement claims sit in two categories. A structure-function claim describes a role in normal physiology: it maintains, supports or contributes to the normal structure or function of the body. A disease claim describes an effect on a disease state: it treats, prevents, cures or mitigates a condition. Collagen peptide, as a food protein, sits firmly in the first category. The line can look thin in everyday language, because supporting joint comfort and relieving arthritis pain sound close, but regulators treat the two categories very differently, and crossing the line can make a food product an unapproved drug in the eyes of the authority.

Wordings that generally fit this category

• Supports skin elasticity and hydration as part of a balanced diet.
• Contributes to the maintenance of normal skin.
• Supports joint comfort and normal joint function.
• Provides protein that contributes to the maintenance of muscle mass, alongside resistance exercise.
• Supports bone health as part of a diet adequate in calcium and vitamin D.

These examples show the general shape rather than an approved list. Each one still has to be checked against the market where it will appear, and some markets provide a defined set of permitted wordings that must be used almost verbatim.

Wordings to avoid

• Any reference to treating, preventing, curing or diagnosing a disease or medical condition.
• References to osteoarthritis, osteoporosis, arthritis or similar named conditions, unless the product is lawfully authorised as a medicine.
• Comparative drug language, such as works like a painkiller or replaces medication.
• Absolute promises, such as removes wrinkles or rebuilds cartilage.
• Testimonials that make a disease claim, because the rules apply to the whole communication, not only the label.

The United States: DSHEA and the disclaimer

For a dietary supplement, US rules allow a structure-function claim without pre-market approval, provided the claim is truthful and not misleading and is accompanied by the standard disclaimer stating that the statement has not been evaluated by the Food and Drug Administration and that the product is not intended to diagnose, treat, cure or prevent any disease. There is also a notification route for claims made for a supplement. Where the product is a conventional food rather than a supplement, the same statement falls under the food labelling framework instead, so the product category changes the answer.

The European Union: only authorised claims

In the EU, nutrition and health claims may only be used if they are authorised and listed in the EU Register of nutrition and health claims. A claim not on the register cannot be used on a food or supplement in the EU, even where it is well supported by studies, and the register wording has to be respected. Most collagen products in the EU therefore rely on already authorised claims, for example claims that protein contributes to the maintenance of muscle mass or to the maintenance of normal bone, with the conditions of use attached to each. Other markets have their own registers, notified lists or self-substantiation systems.

Substantiation and good practice

Whatever the market, a claim should be supported by evidence relating to the ingredient as used, at the dose used, in the population targeted; studies on a different peptide, dose or species do not automatically transfer. Four habits keep claims defensible: keep a claims file with the supporting studies, use the wording exactly as authorised where a market provides it, apply the required disclaimers, and review the file whenever the formulation, dose or label changes. Where the position is not clear, a regulatory adviser or the competent authority is the right place to confirm it. Nothing on a supplier data sheet converts a structure-function statement into an authorised health claim; that decision belongs to the rules of the target market.

Related reading

For more detail, see the EU and US regulatory status of collagen peptides, how batch consistency is controlled and vegan collagen alternatives.