If you work in the food supplement industry or are considering launching a longevity product on the market, there is one thing you must understand: not every promised life-extension constitutes a lawful health claim. Regulation 1924/2006 has very specific requirements on this point, and supervisory authorities in Poland are becoming increasingly active. Let us examine where the gap lies — and how to avoid falling into it.
What is the longevity boom and why the law is struggling to keep pace
Longevity is today one of the most popular terms in the food supplement industry. Manufacturers speak of extending healthspan, delaying ageing, regenerating tissue, and renewing mitochondria. Consumers seek these products with urgency — after all, who would not want to live longer and in better health?
The problem: the majority of these promises constitute health claims within the meaning of Regulation 1924/2006. A health claim is any statement, suggestion, or implication that a relationship exists between a food ingredient, product, and human health. Even if communicated subtly — through words, images, packaging colours, or influencers on Instagram.
The law requires, for any such claim: scientific evidence, assessment by EFSA or another recognised body, and subsequent registration in the European Commission's register. Without this? It is an unlawful health claim, which risks a sales suspension, financial penalty, and removal of the product from the market.
Expert Tip: In practice, manufacturers of longevity food supplements frequently fail to understand the distinction between a health claim (prohibited without registration) and a description of function (permitted). The difference is subtle, but legally critical.
Health claims under Regulation 1924/2006: what is permitted and what is not
Regulation 1924/2006 divides health claims into two categories: general function claims (Articles 13–14) and claims referring to the reduction of disease risk (Article 14(1)(a)).
General function claims must be registered on the EU list. They may relate to bodily functions (e.g. "supports metabolism", "supports the normal functioning of the immune system"), but may not imply treatment, prevention, or reduction of disease risk. If you state "delays ageing" — this sounds like a reduction of the risk of functional decline, which requires a significantly higher standard of evidence.
Disease risk reduction claims require authorisation by the European Commission on the basis of a scientific opinion from EFSA. This is difficult to obtain. For example: EFSA has for many years rejected petitions from food supplement manufacturers regarding the reduction of risk of neurodegenerative or cardiovascular diseases — because the evidence was insufficient.
- "Supports the natural process of cellular regeneration" — a function claim, requires registration on the EU list
- "Reduces the risk of ageing" — a disease risk reduction claim (ageing being a pathological process), requires a scientific opinion from EFSA and authorisation by the European Commission
- "Contains antioxidants" — a description of an ingredient, permitted without registration (provided it is factually accurate)
- "Supports brain function" — a function claim, on the EU list
- "Reduces the risk of dementia" — a disease risk reduction claim, requires a scientific opinion from EFSA
The gap between science and legal requirements: what EFSA actually authorises
This is the crux of the problem: scientific research on longevity does exist. There are in vitro results showing that certain substances (resveratrol, NAD+, metformin) act on cellular models. There are animal studies. There are even epidemiological studies suggesting a correlation between the consumption of certain ingredients and longevity.
However, EFSA, when assessing an application for a health claim, applies very high standards. It requires: randomised controlled trials in humans, a sufficient sample size, an appropriate observation period, and a clear cause-and-effect relationship between the ingredient and the health outcome. In vitro or animal studies are a starting point, not proof.
In practice: EFSA has rejected hundreds of applications from food supplement manufacturers, including those concerning substances that appear promising in scientific publications. The reason: insufficient evidence in humans. For the majority of longevity ingredients (resveratrol, pterostilbene, spermidine, fisetin), there are no authorised health claims in the EU register — despite the existence of scientific research.
- Resveratrol — no authorised health claims in the EU register relating to longevity or ageing
- NAD+ (nicotinamide adenine dinucleotide) — no authorised health claims
- Spermidine — no authorised health claims relating to lifespan extension
- Fisetin — no authorised health claims
- Metformin — this is a medicinal product, not a food supplement, though longevity research is currently in clinical trials
How the Polish Chief Sanitary Inspectorate enforces the rules: practical consequences
The Polish Chief Sanitary Inspectorate (GIS) has the authority to suspend the sale of a product if it bears unlawful health claims. In recent years, there has been a marked increase in the number of enforcement actions — particularly against longevity food supplements and "anti-ageing" products.
The GIS does not wait for a court ruling. It may issue a decision to suspend sales with immediate effect (Article 104 of the Code of Administrative Procedure). The manufacturer may appeal to the Regional Administrative Court (WSA), but until the case is resolved, the product may not be sold.
What does the GIS consider an unlawful health claim? Not only direct statements. Also: suggestions in the product description, images (e.g. a young woman with the caption "regeneration"), citations from scientific studies without context, influencer endorsements on packaging or in promotional materials, and hashtags such as #antiaging or #longevity on the manufacturer's official profile.
Expert Tip: Manufacturers often assume that if a claim appears on a website rather than on the packaging, it is safe. This is incorrect. The GIS treats all of the following as promotional materials: packaging, the manufacturer's website, social media, catalogues, and leaflets. The law prohibits unlawful claims in all of these contexts.
Marketing pitfalls for longevity food supplements: what will not pass an inspection
GIS inspectors read product descriptions from the perspective of an averagely informed consumer. If reading a description implies that the product treats, prevents disease, or extends life — this constitutes an unlawful health claim, even if the manufacturer intended something different.
- "Supports the natural ageing process" — implies a reduction of ageing, prohibited without a scientific opinion from EFSA
- "Regenerates cells" — implies treatment, prohibited
- "Supports mitochondrial function" — if mitochondria are associated with ageing, this may be interpreted as a disease risk reduction claim
- "Contains ingredients studied in the context of longevity" — prohibited, as it implies a connection to lifespan extension
- "Recommended by scientists specialising in ageing" — prohibited, as it implies a health effect
- Images: a young woman, radiance, energy — if accompanied by descriptions such as "regeneration" or "anti-ageing", these constitute a health claim
- Comparison to medicinal products: "works like metformin, but naturally" — prohibited; comparison to a medicinal product implies a therapeutic effect
The most common mistake: manufacturers believe they can refer to "science" and "research" without restriction. They may — but only if doing so does not imply that the product has a health effect. If you write "studies show that resveratrol influences telomere length", and telomeres are associated with ageing — this constitutes a health claim.
How to lawfully bring a longevity food supplement to market without legal risk
If you wish to launch a longevity product, you have several options. Each carries different requirements and risks.
- Option 1: A food supplement without health claims — you describe only the ingredients ("contains resveratrol"), without implying any health effect. Risk: no competitive differentiation, harder to market
- Option 2: Function claims on the registered EU list — e.g. "supports brain function" (if using magnesium or vitamin B). Requires: checking the EU register and confirming the claim is registered there for your ingredient
- Option 3: Submitting an application to EFSA for a new health claim — for new ingredients or new effects. Requires: funding research (sometimes millions of pounds), time (2–5 years), and the risk of rejection
- Option 4: Positioning as a traditional product (if it meets the criteria of Regulation 2004/74/EC) — but this applies to plant-based products, not synthetic longevity ingredients
In practice: most longevity food supplement manufacturers choose Option 1 or 2 — because Options 3 and 4 are too costly and risky. However, this means they must exercise extreme caution in their marketing communications.
Expert Tip: Before bringing a product to market, scrutinise every word in the description from the perspective of the GIS. Ask yourself: would an averagely informed consumer conclude that the product treats, prevents disease, or extends life? If so — revise the wording or add a statement clarifying that the product is not a medicinal product.
The most common manufacturer mistakes and how to avoid them
- Mistake 1: Assuming "scientific" equals "lawful" — research is not the same as an authorised health claim. You may cite studies, but you may not imply that your product has a health effect if the claim has not been authorised
- Mistake 2: Overlooking promotional materials — manufacturers focus on packaging while forgetting that the GIS also inspects websites, social media, catalogues, and emails to distributors
- Mistake 3: Relying on influencers — if an influencer states that your product extends life and you do not prohibit this, you are responsible for that claim
- Mistake 4: Lack of documentation — manufacturers should hold documents confirming that their claims are lawful: printouts from the EU register, legal opinions, and correspondence with the GIS
- Mistake 5: Waiting for a sales suspension — it is far better to be proactive and correct descriptions before a GIS intervention
- Mistake 6: Assuming small businesses will not be inspected — the GIS also inspects small manufacturers and distributors, particularly those selling products online