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Readiness guide · Dietary supplements

New Dietary Ingredient (NDI) Notification Readiness

Decide whether the ingredient is new, build the dossier around the real product and plan launch from the filing date.

4 min readFor regulatory, R&D and quality staff at supplement brands and ingredient suppliers
Softgel filling machine dropping golden capsules from a hopper into white bottles moving along a stainless conveyor, no people

In Short

  1. 1Notify 75 days before sale.
  2. 2The filing date starts the clock.
  3. 3Silence is not acceptance.
Free guide35 pages · Online & printable · 4 worksheets · 21 primary sources · opens online

The Dietary Supplement Operations Guide

What the label says. What the batch proves.

What's inside
  • The rules and who decides
  • Specification to finished batch
  • Test, review, investigate
Get the supplement guide

We ask for your name and email so we can handle this request. The full guide then opens on this site, ready to translate, print or save. Privacy policy. Practical orientation, not legal advice; your quality unit decides which rules apply.

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Free guide

The Dietary Supplement Operations Guide

What the label says. What the batch proves.

QualityTraceabilityPerformance
Contents
  1. When notification applies
  2. What the notification contains
  3. Filing date and the 75 days
  4. Silence is not acceptance
  5. Keeping Product and Dossier Aligned
  6. Questions
Contents
  1. When notification applies
  2. What the notification contains
  3. Filing date and the 75 days
  4. Silence is not acceptance
  5. Keeping Product and Dossier Aligned
  6. Questions

A dietary supplement containing a new dietary ingredient that has not been present in the food supply as an article used for food in a chemically unaltered form needs a premarket notification to FDA at least 75 days before interstate marketing, under 21 CFR 190.6. This guide covers what goes in, how the clock runs and what an FDA silence does not mean. It is orientation, not regulatory advice. Sources checked 4 Oct 2026.

01

When notification applies

Section 190.6(a) applies to a dietary supplement containing a new dietary ingredient that has not been present in the food supply as an article used for food in a form in which the food has not been chemically altered. The manufacturer or distributor of the supplement, or of the ingredient, submits the basis for concluding the supplement will reasonably be expected to be safe.

More on when notification applies

Whether an ingredient is new, and whether the exception applies, is a documented regulatory decision; FDA guidance explains its current views.

02

What the notification contains

Section 190.6(b) lists the contents: name and address of the submitter; the ingredient name, including the Latin binomial and author for botanicals; the level in the supplement and its conditions of use; the history of use or other evidence of safety at those conditions, with copies of cited references and English translations; and the signature of the designated person. Build the dossier around the exact product and conditions of use you intend to sell.

Dossier contents (190.6(b))

0 of 5 in place
03

Filing date and the 75 days

Under 190.6(c), FDA acknowledges receipt and gives the filing date, which is the date FDA receives the notification. For 75 days after the filing date the supplement may not be introduced into interstate commerce.

Worked Example: Ingredient NDI-55

  1. 3 Feb
    FDA receives notification; filing date set
    FDA
  2. 20 Mar
    Extra data sent; FDA rules it substantive
    Regulatory
  3. New filing date
    75-day period restarts
    FDA
  4. After 75 days
    Launch decision recorded
    Regulatory lead
Invented example.
More on filing date and the 75 days

Under 190.6(d), if more information is provided FDA decides whether it is a substantive amendment; if so, a new filing date is assigned and the period restarts. Plan launch from the confirmed filing date.

04

Silence is not acceptance

Section 190.6(f) says that FDA not responding does not mean FDA has found the ingredient or supplement safe or not adulterated. Under 190.6(e) FDA keeps the notification confidential for 90 days after filing, then places it on public display except trade secret or confidential commercial information.

More on silence is not acceptance

Mark confidential material clearly and expect the rest to be public.

05

Keeping Product and Dossier Aligned

A notification covers the ingredient at the level and conditions of use described. A later formula change, a new supplier process or new label directions can take the product outside what was notified.

More on keeping Product and Dossier Aligned

Link the notified specification, supplier and conditions of use to the formula and label in change control, so a person reviews whether a change needs regulatory input before it is made.

How V5 supports this

V5 keeps ingredient specifications, supplier approvals, formulas, labels and change control linked. Your regulatory team decides and prepares the dossier.

  • FormulationIngredient levels by formula version.
  • Approved Supplier ListNotified suppliers on record.
  • Document controlDossier and decisions controlled.

Questions

How long before marketing must we notify?

At least 75 days before introducing the supplement into interstate commerce, counted from FDA's filing date, under 21 CFR 190.6.

Does adding information restart the clock?

Only if FDA decides it is a substantive amendment; FDA then assigns a new filing date.

If FDA does not respond, are we cleared?

No. Under 190.6(f) a lack of response is not a finding that the ingredient is safe.

Where does V5 fit?

V5 keeps ingredient specifications, supplier approvals, formulas, labels and change control linked. Your regulatory team decides whether to notify and prepares the dossier.

Terms
  • NDI Notification
  • GRAS
Industry
  • Dietary Supplements

Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.

Keep reading

  • Dietary Supplement cGMP Readiness: Handoffs and Audit Evidence
  • 21 CFR 111 Readiness: Identity, Master and Batch Records
  • NSF 173 & USP <2750> Readiness: Third-Party Supplement Certification
  • Structure/Function Claims Readiness: DSHEA §6, Disclaimers & Substantiation
  • Supplement Complaint and Adverse Event Reporting Readiness: U.S. Guide
  • Supplement Distribution, Holding and Returned Product Readiness Guide
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Page version 1.4· Last revised 4 Oct 2026