Question regarding proprietary blends

To my understanding ingredients have to be listed by weight in a proprietary blend, is this correct or is there an exception I am missing?

this is referring to blends with no groupings listed like
not like

  1. How must I list proprietary blends?
    You must identify proprietary blends by use of the term “Proprietary Blend” or an appropriately descriptive term or fanciful name. On the same line, you must list the total weight of all “other dietary ingredients” contained in the blend. Indented underneath the name of the blend, you must list the “other dietary ingredients” in the blend, either in a column or linear fashion, in descending order of predominance by weight. These ingredients should be followed by a symbol referring to the footnote “Daily Value Not Established.” Dietary ingredients having RDIs or DRVs must be listed separately and the individual weights declared.

21 CFR 101.36(b)(2) and ©


Thanks, going to have to ask chaoticlabz about one of their products once they get back on it seems.

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Just keep in mind it’s molecular weight in descending order. So while one could be higher/lower in mg/g it could have a higher/lower atomic weight per g.

Stupid question but what in effect does that mean?

Look at caffeine

Now look at theobromine

If both had 100mg in a prop blend, caffeine would have to be listed above theobromine since it has a higher molecular weight.

At least that’s i what I understand according to what the FDA link said. I don’t own a supp company so I can’t confirm lol

I honestly doubt most owners could confirm either.

It doesn’t say molecular weight in the original post you put up. I don’t think that should make a difference tho. If you have a higher total weight of a substance, the number of molecules is irrelevant. Not saying you’re wrong, but that just seems weird to me.

As many company reps/owners are on here, they should know more.

I’m guessing its total weight of the substance, doing some weird atom counting method is unintuitive and wouldn’t work for substances like whey protein which aren’t consistent in their exact make up. I don’t see any reason for it either.

this isn’t correct although it would be pretty cool IMO. if two ingredients are dosed identically in a proprietary blend they can be listed in either position interchangeably

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Well you would be one of those that would know so I’ll trust you on that


My next question here would then be how do some companies get away with listing stuff out of order?

Assuming they aren’t doing something like (((123)5)4) then I’m guessing no one challenging it/being able to tell.

Though what is with HiTech’s lipodrene elite listing stuff out of order?

Well products don’t need to be “approved” prior to being sold same as with general good items. I would bet quite a large sum of money that if you go into a grocery store and used a hplc/gc-ms/lc-ms to check up you’d find more than a handful who aren’t listing ingredients by this requirement.

This doesn’t make it OK…but its the truth.

Supplement companies may list things out of order mistakenly, or more likely due to the fact that there is an extremely low chance someone will test it and catch them in the lie.

While I don’t doubt anything you say, what about those Hi Tech fat burners with the ephedra extracts? They all list the ephedra first, state it’s 25mg, then follow it with acacia or senegalia extracts with a yield of alkaloids in the 150-200mg range. How do they get away with that when they’re even listing amounts?

Here is an example I think you’re referring to. It’s a label for Lipodrene Hardcore with Ephedra

In this instance, from what I have been led to believe, since the amount of Ephedra Extract (25mg) is being stated directly on the label, you can include it in the proprietary blend wherever you choose. It’s when an ingredients dosing is actively hidden/kept secret that it must be included within the normal heaviest to lightest dosing.

Another example can be seen here with Lipodrene with Ephedra which includes the 25mg amount listed both on the label and the nutrition panel


That’s a weird loophole but thanks for explaining.

That makes sense thank you. And yeah that’s what I was talking about!