Dietary Supplements and Influencer Marketing: What Danish Food-Advertising Law Requires

Short answer: a dietary supplement is legally a food, and only EU-approved claims may be used — including spoken ones

A dietary supplement is legally a food in Denmark and the EU, not a category of its own. That means all of its marketing — including an influencer's spoken claim in an Instagram story, a post, or a livestream — falls under the EU's Nutrition and Health Claims Regulation (Regulation (EC) No 1924/2006) and Fødevarestyrelsen's (the Danish Food Authority's) own guidance for influencers and companies, published 24 August 2020. Only nutrition and health claims approved by the EU may be used, and any claim that a product prevents, alleviates or cures a disease is banned — even when the influencer is simply describing a personal experience.

This is practical guidance from Make Influence, not legal advice. Use it to get an overview of what the rules require — get the specific assessment of your exact wording from a lawyer or food-law consultant if there's any doubt.

A dietary supplement is a food, not a special category — and that changes which rules apply

Dietary supplements are regulated as food under the Danish supplements executive order, which implements the EU's Food Supplements Directive. That's an important distinction, because it means marketing a dietary supplement generally follows the ordinary food-advertising rules — not the far stricter medicine rules, which ban all advertising of prescription medicine to the public outright. See influencer marketing in regulated industries: alcohol, finance and pharma in Denmark for the full picture of when that other line becomes relevant: a supplement marketed with a claim that it cures or prevents a specific disease risks being assessed as a medicine by its presentation or function — regardless of how the product itself is registered. That article covers that line. This article covers what applies to the vast majority of dietary-supplement campaigns that never go near it: food law's own, separate regime for which health-related claims may be made at all.

The Claims Regulation: what can an influencer actually say?

The EU's Nutrition and Health Claims Regulation (Regulation (EC) No 1924/2006, often called "anprisningsforordningen" in Danish) establishes that only claims listed on the EU's own register of approved nutrition and health claims may be used in marketing food — including dietary supplements. That applies whether the claim appears on the packaging itself, on the company's website, or in an influencer's post: as Fødevarestyrelsen puts it in its own guidance, the same rules apply to all marketing material.

Disease claims are banned — full stop

It's prohibited to give the impression that a food or dietary supplement can prevent, treat or cure a disease. Fødevarestyrelsen's own guidance for influencers names concrete examples of what can't be said: "Extra vitamin C is good against your cold" is an unlawful disease claim, and the same applies to an influencer who writes something along the lines of "my stomach ache went away" and ties it to the product's effect on a disease-like condition. Fødevarestyrelsen treats this kind of claim as a serious violation in practice, even on a first offence.

Personal testimonials are not exempt

A common misconception is that it's fine as long as the influencer speaks from their own experience ("it worked for me") rather than making a general claim. It isn't. Fødevarestyrelsen is explicit: "Personal accounts and experiences of health effects are not exempt from the rules." An influencer who says their own cold or sinusitis disappeared after taking the product is making the same unlawful disease claim as a general marketing statement would.

Vague health claims with no approved claim behind them don't pass either

It isn't only concrete disease claims that get caught. A 2024 spot check (covered in full below) found that the most common type of violation was actually unspecific health claims — vague wording like "good for your mood" or "good for your gut" that isn't tied to a concrete, approved claim. Fødevarestyrelsen's own head of chemistry and food quality, Henrik Dammand Nielsen, has explained the reasoning: wording like that "can be understood in 100 different ways" — and a claim that can't be traced unambiguously back to the EU's approved list isn't lawful, no matter how innocuous it sounds.

Spoken marketing, stories and hashtags count on exactly the same footing as text

The rules don't distinguish between written and spoken content. Fødevarestyrelsen's own guidance says it directly: "The rules also apply to verbal advertising, for example at events or in stories." An influencer who says an unlawful health claim out loud in an Instagram or TikTok story breaks the rules just as much as if they'd written the same sentence in a caption — there's no "it was only spoken, not written" exception. The same goes for hashtags: a health-related hashtag like "#goodforyourgut" is judged by the same rules as ordinary body text, not treated as an innocent addition sitting outside the claim itself.

Who's responsible? The company's duty, not just the influencer's

Fødevarestyrelsen is unambiguous on this point: the company is fundamentally responsible for ensuring the influencer's posts comply with the rules — regardless of platform, and regardless of whether the collaboration is a paid partnership, a gifting arrangement, a discount code, or simply free product sent for the influencer to try. That extends to situations where someone outside the company tags it in a post carrying an unlawful claim: the company still has a duty to react.

Rulebook	What it regulates	Does it apply to dietary supplements?	Typical mistake
Ad disclosure (Markedsføringsloven § 6(4))	Whether the post is marked as an ad at all	Yes, exactly as with any other paid influencer post	A sponsored supplement review that isn't marked as an ad
The Claims Regulation (1924/2006)	Which health and nutrition claims may be attached to the product itself	Yes — the focus of this article	An influencer says the product "cured" their cold
Medicine advertising rules	Advertising medicine to the public	Only if the product is genuinely presented or functions as a medicine	A disease-curing claim that effectively reclassifies the product as a medicine

Fødevarestyrelsen's five steps for companies

Fødevarestyrelsen's own guidance for companies recommends five concrete steps before an influencer starts posting at all:

1. Explain to the influencer what a claim actually is — most influencers have never heard the term before the collaboration.
2. Build a list of the specific, approved nutrition and health claims that may be used for this particular product.
3. Give examples of lawful phrasing of those approved claims — not just the legal wording, but something an influencer can actually say.
4. Point out the pitfalls specifically relevant to this product (for example, where it's easily confused with treating a disease).
5. Name a contact person at the company the influencer can ask questions along the way.

Tags and comments from others: a rebuttal, not always a deletion

The company's responsibility doesn't stop at its own and the influencer's posts. If a private individual tags (@) the company in a post carrying an unlawful health or disease claim, it's the company's duty to react. For comments from followers on its own posts — for example, a customer writing that the product "cured" their eczema — the recommended approach isn't necessarily to delete the comment, but to reply with a clear disclaimer that distances the company from the unsupported claim. That reflects a free-speech consideration: a customer is entitled to describe their own experience, but the company can't let it stand unchallenged as part of its own marketing.

Enforcement: the 2024 spot check found widespread violations

This isn't a theoretical risk. In 2024, Fødevarestyrelsen ran a spot check of 131 wholesale and retail companies marketing dietary supplements — covering both packaging and digital marketing, including websites and social media. The result, published in February 2025 and covered widely by Danish media (including TV 2 and Kristeligt Dagblad): 80 of the 131 companies — 61 percent — were sanctioned for unlawful claims. Roughly one in five of the inspected companies were fined specifically for illegal disease claims. According to Fødevarestyrelsen's own head of chemistry and food quality, Henrik Dammand Nielsen, the most widespread violation type wasn't the most obvious disease claims but unspecific health claims — vague wording with no approved claim behind it. Fødevarestyrelsen characterised the violation rate as high and noted that compliance was lower than the authority normally sees in food-business inspections generally.

The figure covers companies generally, not influencer marketing specifically — but the inspection explicitly covered digital marketing and social media, and the same claims rules apply identically whether the wording comes from the company itself or from an influencer it has hired.

Decision framework

IF an influencer is going to mention a health or nutrition property of a dietary supplement → give the influencer the specific, approved wording in writing beforehand, rather than simply asking for "something about how it's healthy."

IF the influencer formulates a claim from their own experience ("it helped my stomach") → get it rewritten to an approved claim or removed, regardless of whether the experience is genuine for that individual.

IF someone outside the company tags it in a post carrying an unlawful claim → react actively (remove the tag, or reply with a disclaimer) rather than letting it stand uncommented.

IF you're unsure whether a piece of wording is a banned disease claim or a lawful, approved health claim → get it confirmed by your regulatory function or a food-law consultant before the influencer posts it, not afterward.

Two hypothetical examples (illustrative, not a real Make Influence customer)

The examples below are invented and purely illustrative.

Example A: A supplement brand briefs 15 micro-influencers with a written list of three EU-approved claims for the product ("contributes to normal immune function," one of the actually-approved EU wordings for vitamin C) and concrete examples of how the phrase can sound natural in a story. All 15 posts stick to the list. The campaign complies with the Claims Regulation, however many posts go up.

Example B: Another brand sends the same product to 15 micro-influencers with no list of approved wording — just a general request to "share your honest experience." Two of the 15 write that the product "cured" their cold or "got rid of" their stomach ache. Fødevarestyrelsen doesn't assess just those two problematic posts in isolation — the authority looks at the company's overall marketing (packaging plus social media) as one whole, and the company carries the underlying responsibility for both posts, even though the wording came from the influencers themselves, not the company.

Make Influence's perspective

In our experience, the biggest risk in dietary-supplement campaigns isn't that a brand deliberately wants to break the claims rules — it's that no one has translated the approved, often dryly-worded EU claims into something an influencer can naturally say on camera or write in a story. Left to formulate "something about how it's healthy" on their own, the result often lands closer to a disease claim than either party intended. Our clear recommendation is to treat the written list of approved claims and lawful-phrasing examples as a standing part of the brief — on the same footing as ad disclosure and the other items an influencer contract should cover — rather than something left to the influencer's own judgment along the way.

FAQ

Do these rules also apply to vitamins, protein powder and "wellness" products, not just classic dietary supplements in tablet form?

Yes. The rules apply to any food marketed with a nutrition or health claim — the form (tablet, powder, drink) isn't what matters. What matters is whether the product is legally a food (including a dietary supplement), and whether the marketing contains a claim about a nutritional or health-related property.

Does the post need to be marked as an ad on top of complying with the claims rules?

Yes — these are two entirely separate duties. The claims rules govern which health and nutrition claims may be used. Ad disclosure governs whether the audience can even tell the post is paid content. See influencer marketing disclosure rules in Denmark and the EU for the full disclosure duty.

Do the rules apply if the influencer just got the product for free, with no agreement to post about it?

Yes, if the influencer actually posts about the product. The claims rules are tied to the content of the claim itself, not to whether there's a formal agreement or payment. A free product with no agreement at all can, however, change whether the post needs to be marked as an ad — see the separate disclosure question above.

Can an influencer be held liable themselves, or only the company?

Both can, in principle, be relevant, but Fødevarestyrelsen's own guidance places the fundamental responsibility on the company, because it's the company that initiated the collaboration and gets the commercial benefit from it. That's one reason a written list of approved claims should come from the company itself, not be left for the influencer to research.

What if a claim is approved in another EU country but doesn't clearly show up in Danish practice?

The Claims Regulation is an EU regulation, so the approved list of nutrition and health claims applies across the whole EU in principle, including Denmark. If there's doubt about whether a specific piece of wording is covered, it should be checked with a food-law consultant or Fødevarestyrelsen directly before it's used — not assumed because it's been seen used in another country.

What's the difference between a nutrition claim and a health claim?

A nutrition claim describes a content property of the product (e.g. "high in vitamin C" or "a source of protein"). A health claim describes a relationship between the product or an ingredient and a beneficial effect on the body (e.g. "contributes to normal immune function"). Both types have to be EU-approved to be used — it isn't only health claims that are regulated.

Is there a heightened enforcement risk right now, or was the 2024 check a one-off?

The 2024 spot check is the most recent publicly known inspection of this kind as of this article's publication, but it's part of Fødevarestyrelsen's ongoing supervision of food businesses, not a one-time push. The authority itself has pointed to a need for increased guidance and control in this area — a signal that the level of scrutiny is more likely to rise than fall.

Does this article also cover a dietary supplement marketed as a giveaway or contest prize?

The claims rules covered here apply regardless of format — including when the product is a giveaway prize. A giveaway brings its own, separate rules into play as well: Denmark's spam ban on entry requirements like tagging a friend, and sometimes a Danish prize tax. See how to run an influencer giveaway or contest, legally for those rules.

Do the same documentation requirements apply as for environmental or sustainability claims?

The principle is related — both rulebooks require that a specific claim can be traced back to something documented and approved, not just sound convincing — but they're two separate, independent regimes with their own regulator and list of approved wording. See environmental and sustainability claims in influencer marketing: what Danish law requires for that separate rulebook.

Should brand-safety vetting of an influencer also look at their past dietary-supplement posts?

Yes, that's worth reviewing as part of ordinary brand-safety vetting, particularly if the influencer has previously promoted other supplements or wellness products — a history of loose health claims is a signal worth catching before the contract is signed. See brand safety checklist for influencer partnerships for the full eight-point checklist.

Does this article also cover marketing a restaurant dish or an ordinary food product, not just a supplement?

No — that's a distinct topic with its own dedicated guidance from Fødevarestyrelsen. The claims framework is the same EU regulation, but restaurants and dishes carry an additional, specific rulebook on top of it — for example a ban on labelling a single dish "healthy" or "recommended by dietitians." See marketing food and restaurants through influencers: what Fødevarestyrelsen's claims rules require for that separate guidance.

Are weight-loss drugs like Ozempic or Wegovy covered by this article's rules, since they're sometimes discussed alongside weight-loss supplements?

No — a completely different, far stricter rulebook applies. Ozempic and Wegovy are prescription medicines, not dietary supplements, so they fall under the total ban on advertising prescription medicine to the public, plus a specific ban on using a person of "special esteem" (naming influencers and bloggers explicitly) in a medicine advertisement. See can an influencer legally promote weight-loss drugs like Ozempic or Wegovy in Denmark? for that separate regime, including two real 2024-2025 Danish cases.

Do these rules also apply to a skincare or beauty product, not just something you eat?

No — a topically applied skincare or beauty product is legally a cosmetic product, not a food, and falls under a different EU regulation with its own claims framework (Article 20 of the Cosmetics Regulation and Commission Regulation 655/2013's six common criteria). See substantiating skincare and beauty claims: what EU cosmetics law requires from an influencer's post for that separate rulebook.