Nutrient reference values (NRVs) and maximum levels: a UK and EU reference

Nutrient reference values (NRVs) are the 27 vitamin and mineral reference amounts in Annex XIII, Part A of Regulation (EU) No 1169/2011, identical as of October 2026 in the EU text and Great Britain's assimilated version (Regulation (EU) No 1169/2011, Annex XIII; EUR-Lex, 2025). A supplement label gives each vitamin and mineral per daily dose and as a % NRV, but an NRV is a reference, not a limit: as of October 2026 the EU has set no harmonised maximum levels, and Great Britain sets no statutory ones (Directive 2002/46/EC; Food Supplements (England), (Wales) and (Scotland) Regulations 2003; Council of the EU, 2025).

At a glance

• 27 NRVs: 13 vitamins and 14 minerals, such as 5 µg of vitamin D and 375 mg of magnesium (Regulation (EU) No 1169/2011, Annex XIII).
• Significant amount: as a rule, 15% of the NRV per 100 g or 100 ml (7.5% for drinks) or per single-portion pack (Regulation (EU) No 1169/2011, Annex XIII); "source of" needs it, "high" twice it (Regulation (EC) No 1924/2006, Annex). For supplements we apply it per daily dose.
• EU maximum levels: not set as of October 2026, with no confirmed date (European Commission, 2026; HBW Insight, 2026).
• Science: EFSA's adult upper levels include 100 µg of vitamin D, 12 mg of vitamin B6 and 255 µg of selenium a day (EFSA, 2025).
• US: 25 µg of vitamin D is 500% NRV but 125% of the 20 mcg Daily Value (21 CFR 101.9).

NRV table: every vitamin and mineral in Annex XIII

US Daily Values are for ages 4 and over, as of October 2026 (21 CFR 101.9).

How NRVs appear on a supplement label

Directive 2002/46/EC requires each amount per portion recommended for daily consumption, in numerical form, in its Annex I unit, as an average from the manufacturer's analysis, with vitamins and minerals also as a percentage of the reference values (Directive 2002/46/EC), now those of Annex XIII (Regulation (EU) No 1169/2011, Article 53). As of October 2026, the 2003 regulations for England, Wales and Scotland require the same, with % NRV for each vitamin and mineral in point 1 of Part A, graphical form allowed (Food Supplements (England), (Wales) and (Scotland) Regulations 2003, regulation 6). GB units include µg RE for vitamin A, mg α-TE for vitamin E and mg NE for niacin (SI 2019/651, Schedule 1). Northern Ireland's supplements law falls under the Windsor Framework (FSA, 2018).

Commission guidance applies tolerances over the whole shelf life: for supplements, 20% below to 50% above the declared value for vitamins and 20% below to 45% above for minerals, capped by any harmonised maximum (European Commission, 2012).

The significant amount: 15% of the NRV

As of October 2026, Annex XIII, Part A, point 2 says in both texts that "as a rule" a significant amount is 15% of the NRV per 100 g or 100 ml for products other than beverages, 7.5% per 100 ml for beverages, or 15% per portion if the package holds a single portion (Regulation (EU) No 1169/2011, Annex XIII). A "source of" vitamin or mineral claim needs at least that amount, and "high" twice it (Regulation (EC) No 1924/2006, Annex); health claims add their own conditions (claims and regulation).

Per 100 g, the test says little for a supplement: a 500 mg capsule holding 0.75 µg of vitamin D supplies 150 µg per 100 g, 3,000% of the NRV. EU law provides for minimum amounts per daily portion "to ensure that significant amounts" are present, as does GB law, but neither has set them (Directive 2002/46/EC, Article 5(3); SI 2019/651, regulation 4). Codex guidelines recommend a minimum of 15% of the FAO/WHO recommended daily intake per daily portion (Codex, 2005). We therefore apply 15% of the NRV per daily dose, as our practice rather than a legal threshold.

• Source of magnesium: 56.25 mg a day, about 352 mg of anhydrous trimagnesium citrate at 16% magnesium, or 469 mg of the nonahydrate at 12% (Jungbunzlauer, 2025).
• High in magnesium: 112.5 mg, about 703 mg or 938 mg of those grades.

Maximum levels: where the law stands in October 2026

The EU: provided for, not yet set

Directive 2002/46/EC provides for Commission maximum amounts per daily portion, taking account of upper safe levels, intake from other dietary sources and reference intakes (Directive 2002/46/EC, Article 5). In December 2025, Germany and 16 other member states noted that "no such maximum levels have thus far been set" and asked for them in 2026 (Council of the EU, 2025). On 29 October 2026, the Commission's initiative 12750 on minimum and maximum amounts still listed an unpublished third-quarter 2026 public consultation and adoption in the first quarter of 2028 (European Commission, 2026). In October 2026 a Commission spokesperson told the trade title HBW Insight that "no public consultation is currently planned for 2026", with no further timeline (HBW Insight, 2026).

Member states: national rules meanwhile

Member states may set maximum amounts case by case, on comprehensive scientific risk assessment, with a procedure for supplements lawfully marketed elsewhere in the EU (Court of Justice, 2017).

• France sets maximum daily doses, such as 2 mg of vitamin B6, 15 mg of zinc and 300 mg of magnesium (Arrêté du 9 mai 2006, Annex III). In 2025 the government said they were unchanged since 2006, with a replacement order still under discussion (Assemblée nationale, 2025; Sénat, 2025).
• Germany has proposals, not binding limits (BfR, 2021): the BfR proposes 20 µg of vitamin D per daily dose in supplements for adolescents and adults, as a basis for binding EU levels (BfR, 2024).

Great Britain: no statutory maximum levels

As of October 2026, the 2003 regulations for England, Wales and Scotland control the vitamins, minerals, forms and purity that may be used, and set no maximum or minimum amounts, though SI 2019/651 permits setting both per daily portion (Food Supplements (England), (Wales) and (Scotland) Regulations 2003, regulation 5; SI 2019/651, regulation 4). The Expert Group on Vitamins and Minerals set Safe Upper Levels for eight nutrients, including vitamin B6, zinc and selenium, and guidance levels for 23 others, as risk assessments, not legal limits (EVM, 2003). A voluntary 2004 agreement based on that report set advisory label statements above daily amounts such as 10 mg of vitamin B6, 25 mg of zinc, 20 mg of iron and 400 mg of magnesium (Department of Health, 2011).

EFSA upper levels: the scientific reference

A tolerable upper intake level (UL) is the maximum total chronic daily intake from all dietary sources not expected to pose a risk; where data are too thin, EFSA sets a safe level of intake instead. Adult values from EFSA's overview, version 11 (August 2025), current in October 2026 (EFSA, 2025):

The other NRV nutrients, and beta-carotene, have no UL (EFSA, 2025). EFSA re-evaluated vitamins D and B6, selenium, folate and manganese in 2023, iron, vitamin A, beta-carotene and vitamin E in 2024, and fluoride in 2025, retaining 300 mg for vitamin E (EFSA, 2025; EFSA, 2024). The folate UL covers folic acid and the authorised L-methylfolate salts together (EFSA, 2023a).

One nutrient, six numbers: vitamin D

Permitted forms, and why the form changes the label value

Annex I of Directive 2002/46/EC lists 13 vitamins and 17 minerals and Annex II their permitted forms; GB's lists are Schedules 1 and 2 to SI 2019/651. As of October 2026 the lists differ: the EU's November 2025 text includes calcidiol monohydrate, the monosodium salt of L-5-methyltetrahydrofolic acid, iron milk caseinate and iron hydroxide adipate tartrate (nano), which GB's list, revised in August 2026, does not. GB added magnesium L-threonate monohydrate, listed in the EU since November 2025, in March 2026 for Scotland and Wales and in August 2026 for England (Directive 2002/46/EC; SI 2019/651, Schedule 2).

The label declares the nutrient, not the compound (Directive 2002/46/EC); US rules say amounts "shall represent the weight of the dietary ingredient rather than the weight of the source" (21 CFR 101.36). So 375 mg of magnesium needs about 2.3 g of anhydrous trimagnesium citrate or 3.1 g of the nonahydrate (Jungbunzlauer, 2025); our capsule sizes guide turns that into capsule counts. For calcidiol monohydrate, EFSA proposed a labelling conversion factor of 2.5 against vitamin D3 (EFSA, 2023b).

The US contrast: Daily Values and % DV

A US Supplement Facts panel gives each dietary ingredient per serving and, where a Daily Value exists, its % DV to the nearest whole percent (21 CFR 101.36). Units differ: mcg RAE for vitamin A, mcg DFE for folate, mg NE for niacin, and mcg for vitamin D with IU optional in parentheses (21 CFR 101.9). So 375 mg of magnesium is 100% NRV but 89% DV. As of October 2026, federal law stops FDA setting maximum potency limits for vitamins and minerals in supplements, except for products represented for children under 12, pregnant or lactating women, or specific diseases or disorders (21 U.S.C. 350). See supplement manufacturing for US brands.

Checklist: setting doses across markets

1. Name each nutrient's form and grade, with its content from the certificate of analysis.
2. Check each form against GB's Schedule 2 and the EU's Annex II.
3. Set amounts per daily dose; calculate % NRV and % DV (supplement label requirements).
4. Confirm each claimed nutrient holds 15% of the NRV per daily dose, our basis, or 30% for "high", until expiry.
5. Compare each dose with EFSA's ULs for adults and children and, for GB, the EVM levels and advisory amounts.
6. Check each EU member state's maximum amounts (supplement manufacturing for EU brands), with a lower-dose version or mutual recognition route ready.
7. Size overages from stability data within tolerance, and track the Commission's initiative 12750.

How we approach it at British VitaTech

We set every nutrient between two lines: the source level its claim needs, which we set at 15% of the NRV per daily dose, and EFSA's upper level, with headroom for the strictest market on your plan. For GB we also set doses against the EVM's safe upper and guidance levels (selling supplements in the UK). Our vitamin and mineral supplement manufacturing, multivitamin manufacturing, magnesium and iron supplement manufacturing pages show the forms we use.

Development runs as a paid R&D stage in eight steps, from brief and feasibility to release and handover, with a regulatory and claims review for each market and stability studies in the final pack, at ICH conditions with partner laboratories, that set shelf life and overage (stability and shelf life testing). You receive the formula, specifications, stability data and test reports: your formula is yours.

Every batch is tested by accredited partner laboratories (ISO/IEC 17025), and quality control releases it against its specification with a certificate of analysis (testing and batch release). We draft labels for each market from one formula (label design and artwork), and our regulation watch tracks maximum levels. We are ISO 9001, HACCP and GMP certified by BSI, and FDA registered.

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Sources

1. legislation.gov.uk (2011). Regulation (EU) No 1169/2011 on the provision of food information to consumers, Annex XIII: reference intakes, as it applies in Great Britain (latest available revised version, no outstanding effects; checked 29 October 2026).
2. legislation.gov.uk (2011). Regulation (EU) No 1169/2011, Annex XIII: reference intakes, original text as adopted by the EU (25 October 2011).
3. EUR-Lex (2025). Regulation (EU) No 1169/2011, consolidated text of 1 April 2025 (version 004.001), the latest consolidation on 29 October 2026: cover list of amending acts M1 to M4 and corrigenda C1 to C3.
4. European Union (2025). Directive 2002/46/EC on food supplements, consolidated text of 26 November 2025 (EUR-Lex), amending acts M1 to M13: Articles 5, 8 and 9, Annexes I and II.
5. legislation.gov.uk (2003). The Food Supplements (England) Regulations 2003 (SI 2003/1387), regulation 5: prohibitions on sale relating to composition (latest revised version).
6. legislation.gov.uk (2003). The Food Supplements (England) Regulations 2003 (SI 2003/1387), regulation 6: restrictions on sale relating to labelling (latest revised version).
7. legislation.gov.uk (2003). The Food Supplements (Wales) Regulations 2003 (SI 2003/1719 (W. 186)), regulation 5 (latest revised version).
8. legislation.gov.uk (2003). The Food Supplements (Wales) Regulations 2003 (SI 2003/1719 (W. 186)), regulation 6 (latest revised version).
9. legislation.gov.uk (2003). The Food Supplements (Scotland) Regulations 2003 (SSI 2003/278), regulation 5 (latest revised version).
10. legislation.gov.uk (2003). The Food Supplements (Scotland) Regulations 2003 (SSI 2003/278), regulation 6 (latest revised version).
11. Council of the European Union (2025). Note 15839/25: Maximum levels for vitamins and minerals in food supplements and fortified foods are indispensable (information from Germany, supported by 16 other member states; 10 December 2025).
12. legislation.gov.uk (2006). Regulation (EC) No 1924/2006 on nutrition and health claims made on foods, Annex: nutrition claims and conditions applying to them (GB text, latest revised version).
13. European Commission (2026). Have your say, initiative 12750: Minimum and maximum amounts of vitamins and minerals added to foods including food supplements (initiative record via the portal's public API; type REG; public consultation planned Q3 2026, unpublished; adoption planned Q1 2028; record last modified 17 April 2026; read 29 October 2026).
14. HBW Insight, Citeline (2026). Page error or postponement? Commission says no 2026 consultation planned on EU supplement limits (Tom Gallen, 22 October 2026). Trade press.
15. European Food Safety Authority (EFSA) (2025). Overview on Tolerable Upper Intake Levels as derived by the Scientific Committee on Food (SCF) and the EFSA Panel on Dietetic Products, Nutrition and Allergies (NDA), version 11 (August 2025; the version at this address on 29 October 2026).
16. Cornell Law School Legal Information Institute (2026). 21 CFR 101.9, Nutrition labeling of food: Reference Daily Intakes, paragraph (c)(8)(iv), and footnotes.
17. legislation.gov.uk (2011). Regulation (EU) No 1169/2011, Article 53: repeal (references to the repealed acts construed as references to the Regulation).
18. legislation.gov.uk (2019). The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/651), Schedule 1: vitamins and minerals which may be used in the manufacture of food supplements.
19. Food Standards Agency (FSA) (2018). Food supplements: guidance for businesses (GOV.UK, published 2 July 2018; read 29 October 2026).
20. European Commission (2012). Guidance document for competent authorities for the control of compliance with EU legislation on nutrition labelling tolerances (December 2012; copy hosted by the FSAI).
21. legislation.gov.uk (2019). The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/651), regulation 4: amounts of vitamins and minerals (latest available revised version, no outstanding effects; read 29 October 2026).
22. Codex Alimentarius Commission, FAO and WHO (2005). Guidelines for vitamin and mineral food supplements, CAC/GL 55-2005, section 3.2.
23. Jungbunzlauer (2025). Trimagnesium citrate: anhydrous (16% magnesium) and nonahydrate (12% magnesium) grades (product page, published 10 April 2025).
24. Court of Justice of the European Union (2017). Judgment of 27 April 2017, Noria Distribution, Case C-672/15 (First Chamber).
25. FAOLEX (2006). Arrêté du 9 mai 2006 relatif aux nutriments pouvant être employés dans la fabrication des compléments alimentaires (France), Article 3 and Annex III.
26. Assemblée nationale (2025). Question écrite n° 2211 (17th legislature), answer of the Minister of Agriculture published 11 February 2025.
27. Sénat (2025). Question écrite n° 02957 (17th legislature), ministerial answer published 15 May 2025 (JO Sénat, page 2395).
28. German Federal Institute for Risk Assessment (BfR) (2021). Press release 11/2021: Höchstmengen für Vitamine und Mineralstoffe in Nahrungsergänzungsmitteln und angereicherten Lebensmitteln (16 March 2021).
29. German Federal Institute for Risk Assessment (BfR) (2024). Stellungnahme 007/2024: Aktualisierung (2023), Höchstmengenvorschläge für Vitamin D in Lebensmitteln inklusive Nahrungsergänzungsmitteln (22 February 2024).
30. Expert Group on Vitamins and Minerals (EVM), Food Standards Agency (2003). Safe Upper Levels for Vitamins and Minerals (May 2003).
31. Department of Health, with the Welsh Government and the Food Standards Agency in Scotland and Northern Ireland (2011). Food supplements: label advisory statements and suggested reformulations (voluntary agreement of May 2004; first published September 2011).
32. EFSA NDA Panel (2024). Scientific opinion on the tolerable upper intake level for vitamin E. EFSA Journal 22(8): e8953 (PubMed record).
33. EFSA NDA Panel (2023a). Scientific opinion on the tolerable upper intake level for folate. EFSA Journal (November 2023) (DOAJ record).
34. EFSA NDA Panel (2023b). Scientific opinion on the tolerable upper intake level for vitamin D, including the derivation of a conversion factor for calcidiol monohydrate. EFSA Journal 21(8), 8145 (DOAJ record).
35. legislation.gov.uk (2019). The Nutrition (Amendment etc.) (EU Exit) Regulations 2019 (SI 2019/651), Schedule 2: vitamin and mineral substances which may be used in the manufacture of food supplements (latest revised version, no outstanding effects; timeline to 12 August 2026; annotations F3 and F4 cite SSI 2026/123, WSI 2026/56 and SI 2026/412).
36. Cornell Law School Legal Information Institute (2026). 21 CFR 101.36, Nutrition labeling of dietary supplements.
37. Cornell Law School Legal Information Institute (2026). 21 U.S.C. 350, Vitamins and minerals.