Seven printed, twelve not: reading a panel against an advert

Exhibit 01

Two documents, one folder, two different counts

Nothing here requires an inside view of anything. Both documents were supplied with this stock, both are reproduced on this site, and the whole finding is a count.

The graphic is titled INSIDE GLUCOTIDE and subtitled SIX VITAL NUTRIENTS. It shows six framed cards: vitamin C, vitamin E, biotin, magnesium, zinc and chromium. Each carries its form in a bracket. None carries an amount.

The Supplement Facts panel prints seven nutrients, each with a weight and a percentage of the Daily Value, and then one line reading Proprietary Blend, 82 mg, with 12 ingredients indented beneath it and no weights against any of them.

So the two counts are six and nineteen. The difference splits into two halves: one nutrient the panel prints and the graphic does not, and twelve ingredients no piece of marketing in the folder mentions at all.

Exhibit 02

Manganese, the omitted seventh

One nutrient is on the panel and not on the graphic. It is not a dramatic ingredient, and that is rather the point: the problem is the arithmetic in the subtitle, not the mineral.

The panel prints Manganese (as manganese sulfate), 1 mg, 43% of the Daily Value. It is a printed nutrient with a printed weight and a printed percentage, sitting in the same column as the six that made the graphic. The graphic says SIX VITAL NUTRIENTS.

Be precise about what kind of finding that is. A graphic showing six of seven and saying so would be a selection. One that shows six and announces six, from a label printing seven, is a count that disagrees with its own source document. The subtitle is not incomplete. It is wrong against the panel on the back of the same bottle.

It is a small error, and nobody is harmed by a missing milligram of manganese. What makes it worth a paragraph is that it is checkable in ten seconds by anyone holding both documents.

Exhibit 03

The twelve that appear on no advert at all

The larger half of the gap is not a nutrient count. It is a whole proprietary blend, and it is where the warned-about licorice lives.

The panel gives the blend as one figure: 82 mg for 12 ingredients together. 21 CFR 101.36(c)(3) sets out what that figure means: “The quantitative amount by weight specified for the proprietary blend shall be the total weight of all other dietary ingredients contained in the proprietary blend and shall be placed on the same line to the right of the term 'Proprietary Blend'”. The ordering rule is what makes the list readable: “Dietary ingredients contained in the proprietary blend that are listed under paragraph (b)(3) of this section (i.e., 'other dietary ingredients') shall be declared in descending order of predominance by weight, in a column or linear fashion, and indented under the term 'Proprietary Blend' or other appropriately descriptive term or fanciful name.”

Put the two together and a bound falls out for every member of the list, and the figure below draws all twelve of them. Every step of it is a maximum, never an amount.

Read the top of that profile before the bottom. Licorice is first, so its ceiling is the whole 82 mg, which rules out nothing. The bound only says something further down: 20.5 mg at position four, where the alpha lipoic acid sits, and 6.9 mg at the last. None of these twelve appears on any of the three seller-made panels.

Exhibit 04

What this count does not establish

This is the exhibit that keeps the rest of the post honest. Three conclusions do not follow from anything above, and all three are the conclusions a reader is most likely to reach.

An ordinary explanation fits every fact here. A graphic has finite room; nobody puts nineteen cards on one image. Six framed cards is a design that holds together, the six chosen are the most recognisable names, and the subtitle then counted the cards rather than the panel. This site holds no document that contradicts that account or supports it.

What survives all three subtractions is still worth a reader’s time. The marketing is a selection of the label rather than a summary of it, it leaves out one printed nutrient and one entire blend, and that blend holds the ingredient the bottle prints a warning about. That is a fact about two documents rather than about anyone’s motives.

Exhibit 05

A counting method you can run on any product

The method is arithmetic and takes two minutes. It works on any supplement that publishes both a panel and an advert, and it needs no chemistry at all.

1. Count the advert

   How many ingredients the marketing names, and whether it states that number in a headline. Six here, stated in a subtitle.

2. Count the panel

   The lines with a weight against them, then the indented names under any proprietary blend. Seven and twelve here, which is nineteen.

3. Subtract, and split the difference

   Ingredients the panel weighs and the advert omits, and ingredients inside a blend the advert never mentions. One and twelve.

4. Check whether anything omitted carries a caution

   Read the warnings panel and look for its ingredient in the omitted list. Here the licorice is in the half no advert mentions.

5. Ask the desk what the documents left

   Amounts inside a blend and standardisations are answerable by a person, on +1 (282) 450-4273.

On this product the five steps give: six on the advert, nineteen on the panel, thirteen in the difference, and one of the thirteen carrying the label’s own printed warning. That is a complete reading of two documents by someone with no laboratory and no inside information.