Supplement Semantics: An Experiment on Health Claims

This Article presents original empirical research examining how consumers interpret dietary supplement label claims. Through a controlled experiment with a nationally representative sample, we test the Dietary Supplement Health and Education Act's core assumption - that consumers derive different meanings from various claim types. Our findings reveal a fundamental disconnect: while consumers clearly distinguish disease claims and nutrient content claims, they interpret structure/function claims and health claims as equivalent, despite their vastly different regulatory treatment. These results challenge the regulatory logic of the current four-tiered system and raise significant consumer protection concerns. We propose reforms including consolidating structure/function and health claims into a single category with uniform substantiation requirements, implementing consumer-tested disclosures, and strengthening oversight mechanisms. Without such reforms, dietary supplement regulations will continue to provide only the illusion of consumer protection.