Guide

Supplement claims on TikTok Shop: structure/function vs disease claims

Last checked against the sources below: October 20, 2026. Watchword re-checks these sources every week. This page summarizes FDA’s regulation and guidance, FTC guidance and actions, and TikTok Shop’s US policies. It is not legal advice.

Dietary supplements can carry structure/function claims, such as “supports the immune system,” but not disease claims, such as “reduces cholesterol.” This page sets out, from FDA’s, the FTC’s and TikTok Shop’s own pages, where that line sits, what the FTC says about claims made by paid endorsers, and what TikTok Shop’s supplement rules require. Whether a specific claim, product or video crosses the line is a question for counsel.

The short answer. FDA allows supplements to make structure/function claims, which describe a product’s effect on the body’s normal structure or function, with a disclaimer that FDA has not evaluated the claim. Claims to diagnose, treat, cure, mitigate or prevent disease are not allowed, whether explicit or implied. The FTC’s Health Products Compliance Guidance covers social media and influencer marketing and gives an example where a marketer is liable for a paid blogger’s unsupported cure claim. TikTok Shop’s US supplement rules ban disease claims in listings and allow sales by invited sellers only.

Structure/function claims vs disease claims

Structure/function claims. FDA’s guide describes them as “statements that describe the effect a dietary supplement may have on the structure or function of the body.”
Disease claims. FDA’s guide describes a disease claim as “a claim to diagnose, cure, mitigate, treat, or prevent disease.” A supplement cannot make one.
Implied claims count. The regulation, 21 CFR 101.93(g), lists ten ways a statement can be a disease claim, explicitly or implicitly, including effects on the signs or symptoms of a disease, the product’s name, pictures or symbols, and any statement that “Otherwise suggests an effect on a disease or diseases.”
The disclaimer. A label with a structure/function claim must carry the disclaimer set out in 101.93(c): “This statement has not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.”
Notice and substantiation. FDA says the manufacturer must have substantiation that the claim is truthful and not misleading and must notify FDA of the claim no later than 30 days after marketing the supplement with it. FDA does not pre-approve these claims.

FDA’s own examples

FDA’s Small Entity Compliance Guide on Structure/Function Claims gives paired examples:

Disease claim	Acceptable structure/function claim
“reduces cholesterol”	“maintain cholesterol levels that are already in the normal range”
“Alzheimer’s disease or senile dementias in the elderly”	“mild memory loss associated with aging”
“cystic acne”	“noncystic acne”
“supports the body’s ability to resist infection”	“supports the immune system”
“reduces the pain and stiffness associated with arthritis”	None given

The guide also says context matters: words like “support” or “maintain” are not disease claims on their own, but the surrounding statement can make them one.

What the FTC says about paid endorsers

Influencer content is advertising. The FTC’s Health Products Compliance Guidance (December 2022) says advertising includes statements “in social media and influencer marketing.”
Evidence standard. The guidance says health claims need “competent and reliable scientific evidence” and that anecdotes “are never sufficient to substantiate claims about the effects of a health product.”
The paid blogger example. In Example 40, a marketer pays a blogger to review its supplement, and the blogger writes that it cures acid reflux. The marketer has no evidence for that claim. The FTC says the marketer is liable for the blogger’s misleading representation, and the post must clearly disclose the payment.
Honest opinion is not enough. The guidance says: “It’s not enough that a testimonial represents the honest opinion or experience of an endorser.”

Enforcement involving social media

Amare Global, June 2, 2026. The FTC sued Amare Global, alleging false and unsupported claims that its supplements could help mental health conditions including depression, anxiety and ADHD, including in children. The FTC says the company and its brand partners advertised on Instagram, TikTok, YouTube and Facebook. These are allegations in a complaint filed in federal court in California.
Pharmaganics, September 7, 2021. A joint FDA and FTC warning letter quoted the company’s Instagram and Facebook posts about diabetes and said the claims establish the products as drugs. It was one of ten letters in an FDA and FTC sweep of supplements claiming to treat diabetes.
Teami, March 2020. The FTC sued a tea company over health claims, including that its teas would fight cancer, and over paid influencers who did not adequately disclose payment. FTC staff also sent warning letters to ten influencers. Teami’s teas were not described as supplements in the sources we read.

We did not find an FDA warning letter citing a TikTok post about a dietary supplement as of October 20, 2026.

What TikTok Shop’s supplement rules add

Invite only. TikTok Shop’s US Dietary Supplements Requirements (dated October 9, 2026) say: “Eligibility to sell dietary supplements is limited to invite-only sellers.”
No disease claims in listings. Sellers “may not make explicit or implicit claims that your product diagnoses, cures, mitigates, treats, or prevents any disease or medical condition.” Examples TikTok lists include “Lowers cholesterol,” “Stops hair loss” and “Targets blood sugar levels.”
Implied claims count. TikTok says targeting blood sugar levels “may be considered an implied claim related to diabetes, even if the word “diabetes” is not used.”
No “FDA-Approved.” The page says: “Dietary supplements are not FDA-approved products.”
Disclaimer required. Listings with a structure/function claim must carry the disclaimer on the listing and the label.
Enforcement. A first violation deactivates the listing. A second freezes it until reviewed.
Creator content too. A separate TikTok Shop page, “Requirements for Responsible Health-Related Content” (dated September 2, 2026), says sellers and creators are responsible for complying, and that “Medical claims are prohibited for non-Over-the-Counter (non-OTC) products.” One example of a prohibited claim it gives is “This supplement prevents heart disease.”

What this means for a brand team

A supplement brand can keep its own label and listing inside structure/function claims and still have affiliate creators describe the product in disease terms, such as “lowers my blood sugar” or “cured my anxiety.” In the FTC’s Example 40, a hypothetical, a marketer is liable for a similar claim made by a blogger it paid. Knowing which creator videos about a product use disease language is the starting point for any conversation with counsel about it. For beauty products, see Cosmetic claims vs drug claims in creator videos.

Watchword is built to flag creator videos about your brand on TikTok Shop for your team to review, covering disclosures, product claims, and brand safety. Start with a free Dark Reach Check.

Get a free Dark Reach Check

Common questions

What is a structure/function claim?

FDA describes structure/function claims as statements that describe the effect a dietary supplement may have on the structure or function of the body, such as “supports the immune system.” They need a disclaimer that FDA has not evaluated the claim and notice to FDA within 30 days of marketing.

What is the difference between a structure/function claim and a disease claim?

A disease claim says or implies the product diagnoses, cures, mitigates, treats or prevents disease. FDA’s examples include “reduces cholesterol” as a disease claim and “maintain cholesterol levels that are already in the normal range” as a structure/function claim.

Can a brand be liable for an influencer’s supplement claims?

The FTC’s Health Products Compliance Guidance gives an example where a marketer pays a blogger to review its supplement, the blogger claims it cures acid reflux, and the marketer, which has no evidence for that, is liable for the misleading claim.

Who can sell supplements on TikTok Shop?

TikTok Shop’s US Dietary Supplements Requirements say eligibility to sell dietary supplements is limited to invite-only sellers, and listings may not make explicit or implicit disease claims.

Do TikTok creators have to avoid medical claims for supplements?

TikTok Shop’s “Requirements for Responsible Health-Related Content” says sellers and creators are responsible for complying and that medical claims are prohibited for non-OTC products, giving “This supplement prevents heart disease” as an example.

Sources

This guide summarizes public guidance and public policy pages. It is not legal advice. For decisions about your program, talk to your counsel.