Vitamin A and vision: the approved claim
Futures Nutrition Editorial Team · 13 August 2026
Vitamin A and vision: the approved claim
13 August 2026
The short answer: the official wording is "Vitamin A contributes to the maintenance of normal vision." and it may be used in that form and no other. It applies to any food that is at least a source of vitamin A — that means 120 µg per daily portion, i.e. 15 per cent of the 800 µg reference value. It says something about maintaining a normal function, not about sharper sight, not about tired eyes at the screen, and nothing about eye disease. And it does not distinguish between retinol and beta-carotene, even though that is exactly what makes the difference when you buy: 400 µg of vitamin A as retinyl acetate is a completely different quantity of substance from 400 µg of vitamin A from beta-carotene.
Anyone holding a pack labelled "for the eyes" usually finds this sentence in small print somewhere. It is the only one a manufacturer may write on the subject of vision at all — and it is more precise than it looks at a glance.
The claim word for word — and the other five
The governing text is Regulation (EU) No 432/2012 of 16 May 2012. For vitamin A it lists six approved health claims, each with the same condition of use and with the EFSA opinion it rests on. Vision is one of them:
| Approved claim | Health relationship | EFSA opinion | Register entry |
|---|---|---|---|
| "Vitamin A contributes to the maintenance of normal vision" | vision | 2009;7(9):1221 · 2010;8(10):1754 | 16, 4239, 4701 |
| "Vitamin A contributes to the maintenance of normal skin" | skin | 2009;7(9):1221 · 2010;8(10):1754 | 15, 17, 4660, 4702 |
| "Vitamin A contributes to the maintenance of normal mucous membranes" | mucous membranes | 2009;7(9):1221 · 2010;8(10):1754 | 15, 4702 |
| "Vitamin A contributes to the normal function of the immune system" | immune system | 2009;7(9):1222 · 2011;9(4):2021 | 14, 200, 1462 |
| "Vitamin A contributes to normal iron metabolism" | iron metabolism | 2009;7(9):1221 | 206 |
| "Vitamin A has a role in the process of cell specialisation" | cell specialisation | 2009;7(9):1221 | 14 |
Six sentences, one nutrient — and only one of them is about seeing. That is useful when comparing two products: if a vitamin A claim appears on a pack, it is worth a quick look at which one it is. A manufacturer may advertise with the immune or skin claim without that saying anything at all about eyes.
Which nutrients besides vitamin A may carry the vision relationship at all — riboflavin, zinc and DHA are the others — is set out in Eye nutrients: which claims are approved.
What maintenance of normal vision means physiologically
Behind the wording sits a well-studied mechanism. Vitamin A is the precursor of 11-cis-retinal, the building block of the visual pigment. This molecule sits in the visual purple (rhodopsin) of the rods; when light hits it, it changes shape, the signal arises, and the spent building block must then be returned to its original form in what is known as the retinoid cycle.
How closely this is tied to dark adaptation was set out by Lamb and Pugh in an extensive review: after a strong bleach, the rate at which the eye regains sensitivity is limited by the locally available amount of 11-cis-retinal (Prog Retin Eye Res 2004;23(3):307–380, PMID 15177205). Pronounced vitamin A deficiency is among the states in which this adaptation runs slowly.
From this follows exactly what the approved claim says — and its limit as well. Maintenance is not improvement. Someone who is adequately supplied has no deficit that more vitamin A could fill; the supply of retinal is then not the limiting factor. The German Nutrition Society (DGE) sums up the role just as soberly: vitamin A is important for the visual process, immune function, cell differentiation and embryonic development.
The limits: what may not be said about vitamin A
Alongside the approved claims, the EU register also lists the rejected ones with their original wording and the reason for refusal. For vitamin A several of them are still read, in substance, on packs and in product descriptions:
| Claim as applied for (original wording) | Health relationship | Reason for refusal | Entry |
|---|---|---|---|
| "Necessary for healthy teeth, bones, hair, skin and nails" | bones, hair, nails, teeth | effect not substantiated | 17 |
| "Vitamin A aids healthy bone and teeth growth" | bones, teeth | effect not substantiated | 13 |
| "Necessary to maintain energy and general vitality" | energy and vitality | claim not sufficiently defined | 18 |
| "Vitamin A protects against free-radical-induced muscle damage" | protection against oxidative damage | effect not substantiated | 209 |
The third case is the interesting one: it was not rejected because the effect had been disproved, but because "energy and vitality" was too vague a statement to be assessed at all (EFSA 2010;8(10):1738). That is a different ground for refusal from the other three — and a good yardstick for advertising statements in general: what cannot be measured cannot be authorised either.
Three further limits belong here:
Night vision is not a permissible advertising promise. Not for the plant extracts that stand next to vitamin A in eye preparations either. For a blackcurrant dry extract standardised on anthocyanosides, the claims "Can help to reduce eyestrain" and "Can help to improve night vision" were applied for and not authorised (entry 2750, EFSA 2011;9(6):2204).
Short-sightedness and long-sightedness are not a nutrition topic. They are refractive errors of the eye and are corrected with glasses or contact lenses. The approved claim refers to normal function, not to the dioptre count.
Claims referring to disease are generally not permitted for foods (Regulation (EC) No 1924/2006, Article 12). Food supplements are not medicines; anyone with persistent eye complaints belongs at the ophthalmologist.
Retinol or beta-carotene: the same number, two meanings
For food supplements, Annex II of Directive 2002/46/EC permits exactly four forms of vitamin A: retinol, retinyl acetate, retinyl palmitate and beta-carotene. The first three are preformed vitamin A; beta-carotene is a precursor that the body has to convert first — and with considerable loss.
The D-A-CH reference values therefore work in retinol activity equivalents (RAE):
| Substance | Amount for 1 µg RAE | under the old RE key |
|---|---|---|
| retinol | 1 µg | 1 µg |
| beta-carotene | 12 µg | 6 µg |
| other provitamin A carotenoids | 24 µg | 12 µg |
The right-hand column is the reason for many contradictory table values: older reference works and food composition tables calculate in retinol equivalents (RE) with a factor of 6, the current reference values in RAE with a factor of 12. The same carrot yields half or double the vitamin A depending on the key, without anything having changed about the vegetable.
In practice, for the pack this means: if a product declares 400 µg of vitamin A, that is either 400 µg of retinol, or the corresponding amount of retinyl ester — or around 4.8 mg of beta-carotene. For beta-carotene there is a separate quantitative recommendation on top: the German Federal Institute for Risk Assessment (BfR) proposes a maximum level of 3.5 mg of beta-carotene per recommended daily portion of a food supplement. The background is that the former Scientific Committee on Food (SCF) withdrew the ADI for beta-carotene in 2000; in controlled trials with 20 to 30 mg daily over five to seven years, unfavourable outcomes appeared in people who smoke or work occupationally with asbestos. Since then, 20 mg per day counts as the lowest dose with an observed adverse effect. Anyone who smokes therefore has a concrete reason to look at the beta-carotene line on the label.
How much is in the product — and where the BfR draws the line
The condition for the vision claim is met as soon as the product is a "source of vitamin A". The reference value (NRV) for vitamin A is 800 µg under Annex XIII of Regulation (EU) No 1169/2011; 15 per cent of that is 120 µg per daily portion. That is a low threshold — practically every seriously intended eye product is above it.
Our Vitamin A + E + lutein contains 400 µg of vitamin A per tablet (50 % NRV), plus 20 mg of vitamin E (167 % NRV) and 10 mg of lutein from Tagetes erecta extract. The approved claim on this pack hangs on the vitamin A; the lutein carries none, because the corresponding applications were rejected — as described in Lutein and zeaxanthin: origin, sources, evidence.
At this point a number belongs in the text that is worth knowing: the BfR regards the safety margin for preformed vitamin A as small and names two options — either no addition to food supplements at all, or an addition of up to 0.4 mg per day, which, allowing for an uncertainty factor of 2 for possible multiple use, corresponds to a maximum level of 0.2 mg of vitamin A per recommended daily portion. Products with 400 µg per tablet are therefore above what the BfR proposes; that figure is not a legally fixed maximum but a proposal for future rule-making. The BfR also recommends a note that vitamin A should only be taken during pregnancy after consulting a doctor.
The reference figures behind this:
| Value | Amount | Source |
|---|---|---|
| recommended intake, men 19-65 years | 850 µg RAE/day | D-A-CH 2020 |
| recommended intake, women from 19 years | 700 µg RAE/day | D-A-CH 2020 |
| pregnancy / breastfeeding | 800 / 1300 µg RAE/day | D-A-CH 2020 |
| tolerable upper intake level (UL) | 3 mg/day | SCF 2002 |
| recommendation for post-menopausal women | limit intake to 1.5 mg/day | SCF 2002 |
| BfR proposed maximum level for supplements | 0.2 mg per recommended daily portion | BfR 2024 |
The order of these numbers matters: the UL refers to total intake from all sources, not to the tablet alone. And it does not apply to beta-carotene in any case — provitamin A is converted according to need and is, in this respect, the less problematic route.
What the diet supplies
Retinol occurs almost exclusively in animal foods — above all in liver and the sausage products made from it, and also in fish, cheese and butter. Provitamin A carotenoids come from plant foods such as peppers, pumpkin, apricots and green leafy vegetables. Because vitamin A is fat-soluble, plant sources call for a little fat, say a teaspoon of oil; animal foods bring it along naturally.
How good the supply actually is in Germany is shown by the second national nutrition survey (Nationale Verzehrsstudie II): median total vitamin A intake was between 1.5 and 1.8 mg RE per day in men over 18, and between 1.4 and 1.7 mg RE in women over 18 — in both cases above the D-A-CH recommendations. So vitamin A is not a widespread deficiency here. That does not change the fact that a one-sided diet without liver, dairy and colourful vegetables can look different — it merely shifts the question from "is more better" to "is it enough at all".
Food supplements are not a substitute for a balanced and varied diet and a healthy lifestyle.
What this means at the shelf
- Check which vitamin A claim is on the pack. Six are approved, only one is about seeing.
- Read the form in the ingredients list. Retinyl acetate and retinyl palmitate are preformed vitamin A; beta-carotene is the precursor with a conversion factor of 12.
- Add up the daily total. Vitamin A is also in multivitamin products; the 3 mg UL applies to everything together. What else the range offers on this topic is in the Eyes category.
- Do not forget the second carrier of the statement. Zinc, too, contributes to the maintenance of normal vision — for example in Zinc + vitamin B3 with 25 mg per tablet.
Frequently asked questions
Does vitamin A help with tired eyes after a day at the screen? There is no approved claim for that, and physiologically it is not the right question either: complaints from long screen work depend on blink rate, dryness and near work, not on the supply of the visual pigment's building block. The claims that promised exactly this are recorded in the EU register as not authorised — for blackcurrant extract, for instance, under entry 2750.
Why does it say "µg RE" on some packs and "µg RAE" on others? Because two conversion keys exist side by side. RE converts 6 µg of beta-carotene into 1 µg of retinol, RAE 12 µg. The current D-A-CH reference values from 2020 use RAE; older food composition tables carry RE. With pure retinol the two figures are identical — the difference only arises with plant sources.
Is vitamin A a problem during pregnancy? Requirements are raised in pregnancy (800 µg RAE/day under D-A-CH), while at the same time the DGE advises avoiding regular and excessive consumption of very vitamin-A-rich foods such as liver, especially in the first trimester. The reason is the harmful effect of high amounts of preformed vitamin A on the unborn child. For vitamin-A-containing products the BfR therefore recommends the note about medical advice — which is the right route in this situation, not one's own estimate.
Can the vision claim be put on a product with only 100 µg of vitamin A? No. The condition requires the food to be at least a source of vitamin A, and that is 15 per cent of the 800 µg reference value, i.e. 120 µg per daily portion. At 100 µg the precondition is missing; the amount may be declared, the claim may not.
