Omega-3: what you are actually allowed to say
The counter example to collagen, and a lesson in how little an authorised claim actually claims.
Key takeaways
- EPA and DHA have authorised EU claims, but only in tightly controlled wording and at defined intakes.
- 'Contributes to the normal function of the heart' is not the same as reducing heart attack risk or mortality.
- Large cardiovascular prevention trials of omega-3 supplements have been mixed.
- Most marketing relies on readers interpreting legal claims as stronger than they are.
If collagen shows what an empty register entry looks like, EPA and DHA show what a full one looks like, and the contents are more modest than most readers assume. The EU register carries authorised claims for these two long chain omega-3 fatty acids: that EPA and DHA contribute to the normal function of the heart, permitted where a serving provides a stated daily intake, and that DHA contributes to maintenance of normal brain function and normal vision, again at defined intakes with the information given to the consumer.
Authorisation is not a free hand. Each entry comes with conditions of use, and the legal test for the wording is whether a phrase has the same meaning for the consumer as the approved formulation. That test is why careful labels read like they were written by a committee at the end of a long day. A seller who writes protects your heart has not paraphrased the claim, they have replaced it with a different and unauthorised one. Repetitive and dull is often the sound of compliance rather than of caution.
The substance of the claim deserves the same attention as its wording. Contributes to the normal function of the heart is a statement about maintaining a normal physiological process in people who are getting enough. It is not a statement that supplementation reduces the risk of a heart attack, that it lowers mortality, or that more is better. Large randomised trials of omega-3 supplementation for cardiovascular prevention have been mixed at best, and the evidence does not support reading the label as a promise of protection.
Most people read far more into those words than the words say. That gap between the legal sentence and the imagined one is where most supplement marketing lives, and it does not require anybody to break the rules.
Notes and sources
Each regulatory statement in this article is set against the document it comes from, so you can read the original rather than our summary of it.
1. Authorised claims for EPA and DHA and their conditions of use
Commission Regulation (EU) No 432/2012 establishing a list of permitted health claims
2. Wording may be varied only where it has the same meaning for the consumer
3. Current entries and their required intakes
