Supplement posts by creators in the Netherlands: the claim rules
In the Netherlands, a creator who got your supplement for free may only say what the EU allows you to say. Medical claims are never allowed, a reposted customer message counts as a claim, and the Dutch advertising code makes your brand answer for it too.
The rules in short
- A gifted post is sponsored content. The NVWA (the Dutch food authority) says content rewarded with money or free products is sponsored, and may only contain authorised claims.
- Only EU-authorised health claims. A claim that links the product to health must be on the EU’s approved list. There are no approved claims for probiotics, for example.
- No medical claims, ever. A food or supplement may not claim to prevent, treat or cure anything.
- Testimonials count. A creator’s “since I take it, my belly isn’t bloated” is a health claim, and so is a customer message the brand reposts.
- The brand is responsible too. Under the social media code, the brand and the creator are each responsible, and the brand must actively act against breaches, even when the creator isn’t working on its instructions.
Which rules apply
| Rule | What it says for creator posts | Source |
|---|---|---|
| EU Health Claims Regulation (EC) No 1924/2006, Art. 10(1) | A health claim may only be used if it is authorised. The Advertising Code Committee applies this to Instagram posts. | RCC 2026/00071 |
| NVWA guidance on promoting food online | Content rewarded “in de vorm van geld of gratis producten” (with money or free products) is sponsored content and may only contain permitted claims. Medical claims are never allowed for supplements and sports nutrition. | NVWA |
| Code Aanprijzing Gezondheidsproducten (CAG) | The advertising code for health products: supplements and other foods in pharmaceutical form (capsules, powders, shots) or with a health-related main function. Rules on testimonials, weight loss, endorsements and guarantees. | Reclamecode |
| Reclamecode voor Voedingsmiddelen (RVV) 2026 | For ordinary foods and drinks, such as protein bars or functional drinks. It covers social media and influencers, and allows only authorised health claims. | Reclamecode |
| Reclamecode Social Media & Influencer Marketing (RSM), version of 1 July 2026 | A free product creates a “relevant relationship” that must be disclosed. The brand must make creators aware of the codes and actively act against breaches. | Reclamecode |
What a creator may say about a supplement
A health claim is anything that suggests a link between the product and health. The Keuringsraad, the body that reviews health-product ads, says every claim the European Commission has approved is allowed, and points creators to its claims database. Claims for herbal ingredients (botanicals) are “on hold” at EU level and may only be used with an approved caveat, such as “Gezondheidsclaim in afwachting van goedkeuring door de Europese Commissie”.
| Wording | Why |
|---|---|
| “Vitamine C helpt het immuunsysteem” (vitamin C helps the immune system) | The NVWA gives this as an example of a claim. It is fine when it matches an authorised claim and the product has enough vitamin C. |
| “Ik voel me fit” (I feel fit) | The CAG allows testimonials within the range of normal good health and gives this example. |
| “helpt bij het bestrijden van ontstekingen” (helps fight inflammation) | A medical claim. The NVWA found it in influencer posts in 2025. |
| “zorgt voor toename van energie” (increases energy), “positief effect op de prostaat” (positive effect on the prostate) | Health claims that aren’t authorised, both from the NVWA’s 2025 inspection. |
| “door dit product viel ik in korte tijd 6 kilo af” (I lost 6 kilos in a short time) | The CAG forbids stating how much or how fast weight is lost. |
| “hoog in eiwitten” (high in protein) on a product that doesn’t meet the threshold | A wrong nutrition claim. The NVWA found five of these. |
| “werkzaamheid gegarandeerd” (effectiveness guaranteed), “blijvend resultaat” (lasting result) | The CAG forbids guaranteeing an effect. |
Other CAG rules creators run into
- No endorsement by health professionals or well-known people. Article 17 rules out recommendations by doctors, pharmacists, dietitians and physiotherapists, and by people whose fame could drive use. White coats count as an indirect endorsement.
- No “veilig” (safe) without context. “Veilig indien gebruikt volgens gebruiksaanwijzing” (safe if used as directed) is the allowed form.
- No “natuurlijk” (natural) as proof of safety or effect, unless it is proven and sets the product apart.
- Not aimed at children of 12 and under.
What the NVWA found in creator posts
From June to August 2025, the NVWA checked 41 Instagram posts about food by 15 influencers. 23 posts by 10 influencers contained prohibited claims: 18 unauthorised health claims, 5 wrong nutrition claims, and medical claims from 2 influencers. The products included fish oil and protein powder. All 15 influencers had a certificate from Influencerregels.com.
The NVWA didn’t take action in that study, but said it may in later ones, and announced a broader inspection of misleading food claims by influencers for the following year. Its guidance says it can fine anyone who uses misleading or prohibited claims.
Two 2026 rulings on supplement posts
- 01
A reposted customer message is a claim (RCC 2026/00071, 8 April 2026)
A founder reposted a follower’s message in an Instagram Story about the brand’s probiotic capsules: daily bowel movements “sinds een capsule van je Gut formule”, and no more bloating. The Keuringsraad complained. The committee held that the testimonial, the product name “Gut Formula” and the promotional use of “probiotica” were health claims, and that there are currently no authorised claims for probiotics. Read the ruling.
- 02
A contract clause isn’t enough (RCC and appeal board 2025/00594, 22 April 2026)
A brand partner of Amare posted a Story saying its Happy Juice supplements could help the immune system and gut flora and stimulate brain function. The appeal board held the brand co-responsible: a commission on sales is a relevant relationship. A contract banning unauthorised claims, factsheets, trainings and one reminder were not enough, because the code asks for active, decisive action. Read the ruling.
The Keuringsraad draws the lesson in its influencer guidance: the creator and the brand are both responsible, and subtle wording, implied suggestions and personal testimonials can easily count as a claim.
Pre-approval by the Keuringsraad
The Keuringsraad KAG reviews health-product ads before they run, including posts on websites and social media, usually within 5 working days. An approved ad gets a number to show on it, generally valid for one year. Under the CAG, the committee takes a valid approval number into account. We found no rule that makes pre-approval compulsory for every supplement ad, but many retailers and media ask for the number. The Keuringsraad also monitors ads that were never submitted, and can pass them to the NVWA or the committee.
Disclosure comes on top
A claim that is allowed still needs a label. Under the RSM, a free product sent so the creator posts about it creates a relevant relationship, with no follower minimum. A gift can be labelled “gekregen van @brand”, a paid post “Advertentie”, “Reclame” or “ad” with the brand named, as the first word of each text block. Full details are in our guide to influencer disclosure in the Netherlands.
What your brand should do
- 01
Send the allowed claims with the product
Give each creator the exact authorised wording for your product, in Dutch, and say what not to say: no medical effects, no weight-loss amounts, no guarantees. The NVWA also tells creators to ask the supplier for a claims report.
- 02
Point them to the codes in writing
The RSM asks brands to make creators aware of the code. Without a contract, the brand must point gifted creators to it explicitly when inviting them to share their view.
- 03
Check what was said, not just whether they posted
Claims hide in voice-overs and testimonials as much as in captions. Look at every post your product appears in, tagged or not.
- 04
Act fast and keep a record
Ask for a fix or removal when a post crosses the line, and note what you asked and when. The Amare ruling shows that a clause in a contract and one reminder are not enough.
- 05
Don’t repost customer claims
A testimonial you share becomes your own claim, as the Gut Formula ruling shows.
How Pozto helps
Pozto watches the creators you gifted on TikTok, Instagram Reels and YouTube Shorts and finds the posts that show your product, tagged or not. For each post you see the caption, and on Starter and up, every time your brand or product is said out loud, with the creator’s words and the second. That is where claims like “mijn buik is niet meer opgezet” turn up.
Pozto doesn’t judge claims. It gives your team one list of every post to review, instead of hunting for posts you didn’t know about. It also grades disclosure: in Settings, under “Disclosure rules”, set “Grade posts by the rules of” to the Netherlands, and Pozto checks each caption for the Dutch labels. Start free with up to 10 creators, or see Pozto for supplement brands.
Questions
Can an influencer make health claims about a gifted supplement in the Netherlands?
Only claims authorised by the EU, in line with the approved wording. The NVWA says content rewarded with free products is sponsored content and may only contain permitted claims. Medical claims are never allowed.
Is a personal testimonial a health claim?
It can be. In RCC 2026/00071, a reposted customer message about daily bowel movements and less bloating was held to be a health claim. The CAG allows testimonials only within normal good health, such as “Ik voel me fit”.
Is the brand responsible for what a creator says?
Yes. Under the RSM, the brand and the creator are each responsible, and the brand must actively act against breaches. In the Amare case, the appeal board held the brand co-responsible for a partner’s Story.
Do supplement posts need Keuringsraad approval?
We found no rule that makes it compulsory for every supplement ad. The Keuringsraad reviews social posts on request, and the committee takes an approval number into account. Many retailers and media ask for one.
Are there approved health claims for probiotics?
No. In April 2026 the Advertising Code Committee noted there are currently no authorised health claims for probiotics, so promoting “probiotica” for gut health is not allowed.
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