Buying eye supplements: label, amount, combination
Futures Nutrition Editorial Team · 14 August 2026
Buying eye supplements: label, amount, combination
14 August 2026
The short answer: three details decide it, and all three are on the back. First, the amount per daily portion — not per tablet, and not what is advertised in large type on the front. Second, whether the product contains one of the four nutrients that may say anything about vision at all: vitamin A, riboflavin, zinc, DHA. Third, what else is taken every day — the reference values apply to the total. The peculiarity of eye supplements: the substance with the biggest appearance on the front is usually lutein, and that is precisely where there is no percentage figure, no authorised claim and no upper limit. That is not a labelling defect, it is the legal position — one simply has to know that the decision therefore hangs on other lines.
Eye supplements are almost always combinations: two carotenoids, two to four vitamins, a trace element, sometimes an omega-3 oil. It is this variety that makes comparison on the shelf laborious, because every pack makes a different selection. The order below makes it short.
What has to be on every pack
Food supplements in Germany are governed by the food supplements ordinance (Nahrungsergänzungsmittelverordnung, NemV). Its § 4 lists what has to appear on the packaging in addition to the general labelling requirements of Regulation (EU) No 1169/2011:
| Mandatory detail | Legal basis |
|---|---|
| the designation "food supplement" | NemV § 4 (1) |
| the names of the nutrient categories that characterise the product | NemV § 4 (2) no. 1 |
| the recommended daily amount, expressed in portions | NemV § 4 (2) no. 2 |
| "The stated recommended daily intake must not be exceeded." | NemV § 4 (2) no. 3 |
| a statement that the product is not a substitute for a balanced and varied diet | NemV § 4 (2) no. 4 |
| a statement to store out of the reach of young children | NemV § 4 (2) no. 5 |
| the amount of nutrient per daily portion as an average value from analysis | NemV § 4 (3) no. 1 |
| the percentage of the nutrient reference value — in so far as a reference value has been laid down | NemV § 4 (3) no. 2 |
The last row is the most important one for eye supplements, and that is because of its qualifier. The percentage is only required for those substances for which Annex XIII Part A of Regulation (EU) No 1169/2011 lays down a reference value — and those are exclusively vitamins and minerals. Lutein and zeaxanthin are neither. Behind "10 mg lutein" the percentage is therefore not missing; there simply is none. Anyone sorting packs by how complete the percentage column is will, with eye supplements, be sorting the wrong thing.
Also tucked away in § 4, paragraph 4: a food supplement may not be advertised with the claim that a balanced and varied diet cannot generally provide an adequate supply of nutrients. A pack that asserts exactly that is in breach of the ordinance — a usable filter before it even comes to numbers.
The amount: per daily portion, not per tablet
All the mandatory details relate to the daily intake stated on the label. Whether that portion consists of one capsule or of three is in the line above. Two packs with apparently identical figures can therefore differ by a factor of three — and the supply accordingly.
With the carotenoids there is a second trap. In supplements lutein is often used as lutein ester, and the ester weighs almost twice as much as the lutein in it: the lutein share is around 54 per cent, so 20 mg of ester amounts to about 11 mg of lutein. Where the front shows the larger figure, that is not an advantage but a different basis of reference. Whichever of the two a label states, it is the free lutein that has to be compared.
With zinc and vitamin A the reverse applies: what is declared is always the nutrient, not the compound. "25 mg zinc from zinc gluconate" means 25 mg of zinc, not 25 mg of gluconate.
The four figures an amount can be measured against
Once the figure has been found, the actual question follows: is it a lot or a little? For that, four reference figures stand side by side that mean different things and are regularly confused.
| Nutrient | 15 % NRV = condition for the claim | NRV (label basis) | BfR maximum level proposal per daily portion | UL (total intake) |
|---|---|---|---|---|
| Vitamin A (preformed) | 120 µg | 800 µg | 0.2 mg | 3,000 µg |
| Riboflavin (B2) | 0.21 mg | 1.4 mg | no proposal needed | none derived |
| Zinc | 1.5 mg | 10 mg | 6.5 mg | 25 mg |
| Vitamin E | 1.8 mg | 12 mg | 30 mg | 300 mg |
| Lutein / zeaxanthin | — | none laid down | none | none |
The columns read as follows. The 15 per cent threshold is the lower limit above which a nutrient may be named on the label at all. The NRV is a pure calculation figure for the percentage statement, not a recommendation. The BfR proposal is a recommendation from the German Federal Institute for Risk Assessment to the legislator for the addition of a nutrient to food supplements; binding EU maximum amounts for vitamins and minerals are indeed provided for in Directive 2002/46/EC, but to this day they have not been set. The UL, finally, is the tolerable total intake from all sources, food included.
Two rows deserve a second look. With vitamin A the BfR proposal and the UL are a factor of 15 apart, because the institute takes into account the small safety margin over customary intake and additionally deducts an uncertainty factor of 2 for multiple use; it expressly names two options — no addition to supplements, or addition up to 0.4 mg per day, which corresponds to 0.2 mg per recommended daily portion. Alongside that it recommends a note that vitamin A should be taken in pregnancy only after consulting a doctor. In practice the upper limit is exceeded via liver, not via tablets.
With riboflavin both right-hand columns are absent: neither the SCF nor EFSA has derived a UL, and the BfR expressly refrains from a maximum level proposal for vitamins B1 and B2 and for pantothenic acid, because no adverse effects have been observed even far above the intake recommendations. A three-digit percentage for B2 is therefore not an alarm signal — it is only a high percentage.
The combination: where the total gets tight
Eye supplements rarely stand alone in the cupboard. Zinc sits in multivitamins, in hair-skin-nails combinations and in immune products; vitamin A in multi-preparations and in cod liver oil. And because the mandatory declaration under § 4 (3) NemV uses the same basis in every product — the amount per daily portion — the total is easy to form: put the labels side by side, add up, compare with the right-hand column of the table.
| Example daily combination | Zinc | Vitamin A |
|---|---|---|
| eye combination product | — | 400 µg |
| single-nutrient zinc product | 25 mg | — |
| multivitamin-and-mineral tablet | 10 mg | 800 µg |
| Total | 35 mg | 1,200 µg |
| for comparison: UL | 25 mg | 3,000 µg |
The figures are calculated, not measured — they only show where it gets tight and where it does not. For vitamin A the total stays clearly below the upper limit; for zinc it lies above it, and that without any single product being conspicuously high in dose. It is precisely for that reason that the BfR recommends, for products with more than 3.5 mg of zinc per daily dose, a note advising against further zinc-containing food supplements. The practical conclusion is not a warning but an arithmetic one: anyone taking a zinc product strikes the zinc out of the second source.
For lutein and zeaxanthin this calculation falls away for want of a reference figure. The only quantitative point of reference is EFSA's ADI of 1 mg of lutein per kilogram of body weight from Tagetes erecta — at 70 kg, therefore, 70 mg a day, a multiple of customary supplement amounts. For synthetic zeaxanthin a limit of its own applies: it is authorised as a novel food up to 2 mg per day.
What the pack is allowed to say
On vision, exactly four claims are authorised in the EU, all of them in Regulation (EU) No 432/2012 and all in the same sentence pattern: Vitamin A contributes to the maintenance of normal vision. Riboflavin contributes to the maintenance of normal vision. Zinc contributes to the maintenance of normal vision. DHA contributes to the maintenance of normal vision. For lutein and zeaxanthin, corresponding applications were assessed and not authorised.
A frequent companion in eye combinations is vitamin E. It carries an authorised claim of its own, but one that says nothing about the eye: Vitamin E contributes to the protection of cells from oxidative stress. It applies to cells in general.
Where an authorised claim is used, Article 10(2) of Regulation (EC) No 1924/2006 requires four further pieces of information on the labelling: a statement on the importance of a varied and balanced diet and a healthy lifestyle, the quantity of the food and the pattern of consumption required, where appropriate a statement addressed to persons who should avoid the food, and a warning for products that might present a health risk if consumed to excess. Article 12 of the same regulation excludes claims which refer to the prevention, treatment or cure of a disease — eye diseases included. Food supplements are not medicines; anyone noticing symptoms should have them clarified by an eye doctor.
Supply and price per day
For a price comparison the pack price is useless as long as the supply it covers is unknown. The calculation has two steps: the number of units divided by the daily intake gives the number of days, the pack price divided by those days gives the price per day. A tub of 180 tablets with one tablet a day lasts half a year; a pack of 60 capsules with two capsules a day, one month.
Our Vitamin A + E + lutein is an example of the simple case — one tablet a day, 180 units per tub, and so a half-year supply.
| Per tablet (recommended daily dose) | Amount | % NRV* |
|---|---|---|
| Vitamin A | 400 µg | 50 % |
| Vitamin E | 20 mg | 167 % |
| Lutein (from Tagetes erecta extract) | 10 mg | — |
* Nutrient reference values in accordance with Regulation (EU) No 1169/2011, Annex XIII. For lutein no reference value has been laid down.
The table shows the three cases side by side: the vitamin A, at 400 µg, is above the 15 per cent threshold of 120 µg — the vision claim is thereby covered — and at the same time above the BfR proposal of 0.2 mg, at around 13 per cent of the upper limit of 3,000 µg. The vitamin E, at 20 mg, stays below the BfR proposal of 30 mg. And with the lutein the percentage column stays empty, because there is nothing there to fill it with. Whether the tablet is taken with a meal containing fat decides more about absorption than the time of day does.
Anyone wanting to cover the vision claim via zinc rather than via vitamin A will find in Zinc 25 mg + vitamin B3 25 mg of zinc from zinc gluconate per tablet (250 % NRV) — well above the 1.5 mg from which the zinc claim may be used, and at the same time at the level of the UL of 25 mg. Anyone combining both products has the claim covered twice over and, for zinc, no room left for a third product.
What else the range holds on this subject is shown by the category Eyes; the single-nutrient zinc products are under Zinc. Food supplements are not a substitute for a balanced and varied diet and a healthy lifestyle.
The order of checks at the shelf
- Find the daily portion. One tablet or three? Every figure that follows hangs on it.
- Look for the four nutrients. Vitamin A, riboflavin, zinc, DHA. If none of them is in the table, there is nothing permissible to be said about vision — regardless of the amount of lutein.
- Check the 15 per cent threshold. 120 µg vitamin A, 0.21 mg riboflavin, 1.5 mg zinc. Below that the nutrient may not be named on the label.
- Lutein: ester or free? 20 mg of ester is around 11 mg of lutein.
- Add up secondary sources. Zinc above all. The total counts, not the individual tub.
- Work out the supply. Number of units divided by the daily portion, price divided by days.
Frequently asked questions
Is a product with 20 mg of lutein better than one with 10 mg? It contains more lutein — provided both figures relate to free lutein and not, in one case, to the ester. No authorised claim justifies the higher amount, and there is likewise no upper limit against which it could be measured. The widespread 10 mg of lutein plus 2 mg of zeaxanthin come from the study protocol of AREDS2, not from a requirement laid down by any authority.
Why is the percentage missing for lutein? Because § 4 (3) no. 2 NemV requires the percentage only in so far as a reference value has been laid down in Annex XIII Part A of Regulation (EU) No 1169/2011. That is the case only for vitamins and minerals. The statement "10 mg" is therefore complete.
Do I have to count the zinc from my multivitamin as well? Yes. The tolerable total intake of 25 mg applies to the sum from all sources. Both labels state the amount per daily portion, so they can be added up — and above 3.5 mg of zinc per daily dose the BfR recommends a note advising against further zinc-containing products anyway.
Does "high-dose" on the pack tell me anything? No, the term is not defined. An amount can only be placed in context by the four reference figures: 15 per cent of the NRV as the lower limit for naming the nutrient, the NRV as a calculation figure, the BfR proposal for addition to supplements, and the UL for total intake.
Sources: German food supplements ordinance (NemV) § 4 paragraphs 1 to 4 (mandatory details, wording of the warning, amount per daily portion, percentage only where reference values have been laid down, advertising prohibition under paragraph 4); Regulation (EU) No 1169/2011, Annex XIII Part A (nutrient reference values vitamin A 800 µg, riboflavin 1.4 mg, zinc 10 mg, vitamin E 12 mg; no reference values for lutein and zeaxanthin); Regulation (EC) No 1924/2006, Article 10(2) and Article 12 (accompanying information, exclusion of disease-related claims); Regulation (EU) No 432/2012 (official wording of the vision claims for vitamin A, riboflavin, zinc and DHA as well as of the cell-protection claim for vitamin E); Directive 2002/46/EC (maximum amounts provided for but to this day not laid down); German Federal Institute for Risk Assessment, maximum level proposals for vitamin A (0.2 mg per recommended daily portion, note for pregnancy), for vitamin E (30 mg) and for zinc (6.5 mg, recommended note from 3.5 mg) as well as opinion on vitamins B1 and B2 and pantothenic acid (no maximum level proposal required), summarised in Opinion 006/2024 of 22 February 2024; SCF (2002/2003) and EFSA (2024) on the ULs for vitamin A (3,000 µg), vitamin E (300 mg) and zinc (25 mg); EFSA on the ADI for lutein from Tagetes erecta (1 mg/kg body weight); authorisation of synthetic zeaxanthin as a novel food up to 2 mg daily; AREDS2, JAMA 2013;309(19):2005–2015 (origin of the amounts 10 mg lutein and 2 mg zeaxanthin); lutein share of the dipalmitate calculated from the molar masses; composition and recommended intake of the products named according to the label.
