California clarifies date-labeling rules for supplements

WASHINGTON — California has exempted dietary supplements from the state’s standardized food date-labeling requirements, providing manufacturers and retailers with clarity on how expiration and shelf-life information can appear on supplement products.

AB 2779 expressly excludes dietary supplements from the definition of a “food item for human consumption” subject to the state’s date-labeling requirements. The Council for Responsible Nutrition said it advocated for the clarification after uncertainty arose over whether supplements could be covered by rules originally established under AB 660.

Without the exemption, supplement manufacturers could have faced changes to established expiration and shelf-life labeling, including the use of terminology such as “BEST if Used by” and “USE by” that was developed for conventional foods.

CRN argued that applying those requirements to supplements could create confusion because supplement expiration dates communicate shelf life and ingredient potency rather than the food-safety distinctions addressed by California’s standardized labeling system.

“This was not simply a technical correction,” said Steve Mister, president and CEO of CRN. “Without a clear exemption, responsible supplement manufacturers faced the prospect of changing labels to comply with requirements that were written for conventional foods and were never intended for our products. Those changes could have disrupted longstanding practices for communicating shelf life and potency while making the information less—not more—meaningful to consumers. CRN worked to make sure that unintended outcome did not occur.”

CRN had been involved in the issue since California considered AB 660, enacted in 2024. The association said that discussions during that process indicated that dietary supplements were not intended to fall within the legislation’s scope. CRN subsequently advocated for AB 2779 to make that distinction explicit in state law.

The association also pushed for an urgency clause allowing the clarification to take effect immediately, avoiding a period during which companies could have faced decisions about labels, packaging and other compliance measures before the legislation’s ordinary effective date.

“This is precisely why CRN maintains an aggressive state advocacy program,” said Julia Gustafson, vice president, government relations at CRN. “A law may be written with conventional foods in mind, but if the statutory language inadvertently captures dietary supplements, our members can suddenly face significant compliance uncertainty and unnecessary operational changes. Our job is to identify those consequences and get them corrected.”