Supplement Facts label software built from the formula

The panel should be an output of the record

A Supplement Facts panel is often maintained as a separate design artifact. That creates two versions of the product: the formula that will be made and the label values that will be printed. Each revision requires someone to reconcile them again.

ERRA derives the panel from the approved formula version. The same ingredient amounts and composition facts feed the declared values, serving information, allergen statement, claim checks, and cost calculation. A formula change produces a new version and a new output, while the previous record remains intact.

What ERRA calculates and records

• Supplement Facts panels under 21 CFR 101.36 and Nutrition Facts panels under 21 CFR 101.9.
• Declared amounts and percent Daily Value using deterministic rounding rules.
• Allergen statements derived from ingredient and supplier records.
• Free-from and dietary claim checks against the formula facts held in the system.
• Print-ready PDF output tied to the formula version that produced it.
• A comparison path for reviewing generated output against an existing approved label.

Automation does not replace review

Panel math can be deterministic while the underlying source data remains incomplete or disputed. Ingredient composition, serving basis, regulatory classification, and source documents still require qualified human review. ERRA records those inputs and decisions; it does not provide legal advice or make the responsible company's regulatory determination.

The useful control is traceability from each displayed value back to the formula and source facts. A generated panel without that path is another detached file.

Questions to ask during an evaluation

• Does the panel recalculate directly from a versioned formula?
• Are rounding rules deterministic and testable?
• Can each displayed amount be traced to ingredient composition and formula quantity?
• Does the system distinguish missing evidence from a passing check?
• Are allergens and claims derived from the same ingredient record used by the formula?
• Does the exported panel identify the formula version behind it?

Primary sources

• 21 CFR 101.36: nutrition labeling of dietary supplements
• FDA dietary supplement labeling guide
• 21 CFR 101.9: nutrition labeling of food

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