Nutritional Information

Nutritional labelling for supplements was developed to give consumers a clear, regulated understanding of the nutrient content of standardised synthetic supplements.

However, when it comes to traditional, nutrient-dense whole foods, such as fermented cod liver oil or concentrated butter oil,the limitations of nutritional labelling become apparent. These products more closely resemble foods due to their naturally occurring nutrients, lack of heavy processing and no standardisation with synthetic/ artificial nutrients. However, because of their rich and diverse nutritional profile, these foods are commonly consumed to supplement diets, often in capsule form. Due to this, they are treated as dietary supplements, not foods, when it comes to labelling. Unfortunately, their complexity cannot be meaningfully captured within the rigid framework of standard supplement labelling.

Labelling Limitations

Fixed Values

One major limitation is the requirement to list fixed values for nutrients. While regulations allow for some degree of variance or tolerance, this is still a narrow range that does not accommodate the broader, natural variation seen in whole food products. For example, the vitamin A or vitamin D content in cod liver oil can vary depending on the season, age, sex, diet and general health of the fish. A single declared number on a label cannot reflect this variability, and it gives the misleading impression of uniformity when none exists.

Over Simplified

Another important limitation is that nutrient labelling is built around a simplified model of nutrition. It typically requires manufacturers to report isolated nutrients in a single chemical form, such as “vitamin D3 (cholecalciferol).” However, this does not reflect the full nutritional profile of a food like cod liver oil or butter oil, which naturally contain a range of vitamin D-related compounds, including 25-hydroxyvitamin D3 and 1,25-dihydroxyvitamin D3, among others. These metabolites play different but complementary roles in the body’s use of vitamin D, supporting immune function, calcium metabolism, and cellular signalling. Listing only vitamin D3 (cholecalciferol) excludes this nutritional nuance and undervalues the biological richness of these foods.

The same can be said for omega-3 fatty acids. The most granular labelling focuses on EPA and DHA, which are, of course, very important, but there are more omega-3 fats present in natural cod liver oil. Fermented cod liver oil is a rich source of the omega-3 fats EPA and DHA, which make up approximately 80% of the omega-3 content, while the remaining 20% consists of a variety of lesser-known but important fatty acids, including docosapentaenoic acid (DPA) and stearidonic acid (SDA). These additional omega-3 fats contribute meaningfully to the anti-inflammatory, cardiovascular, and neurological benefits attributed to natural marine oils.

By focusing narrowly on isolated nutrients, standard labelling frameworks fail to capture the synergistic complexity of traditional foods like fermented cod liver oil. In reality, it is the full matrix of vitamins, co-factors, and a diverse range of fatty acids – in their natural, unmodified forms – that underpins the oil’s historical and continuing reputation for supporting health.

The current labelling model is well-suited to synthetic or highly processed products that contain known, standardised quantities of nutrients. But it is not an appropriate fit for traditional whole food concentrates that are used for their broad and complex nutritional profiles. Attempting to reduce such foods to a set of fixed values can misrepresent their true character and benefits.

Previously, we had displayed nutritional information on our label based on averages of tested nutrients such as “vitamin D3 (cholecalciferol)”, as shown in the label below. However, we felt this didn’t represent the product properly, and was not accurate for the nature of our product.

For this reason, we have kept our labelling on these products intentionally concise and minimal. We meet regulatory requirements, but we do not attempt to use the label as the primary space to communicate the full nutritional value of these complex, naturally derived products. Instead, we have created this dedicated space on our website to offer more informative and transparent content.

Here, we are able to share deeper insights into the nutritional profile, of foods like cod liver oil and butter oil—information that is too nuanced and variable to fit within the constraints of standard nutritional labelling.

Supplement or Food?

Butter oil is a good example of how the format of a product,  rather than its composition, can determine how it is regulated and labelled. When butter oil is presented in a dosage form, such as capsules, it is legally classified as a dietary supplement and must adhere to supplement labelling regulations. However, when the same butter oil is offered in a non-dosage form, such as a jar, where the consumer self-serves by scooping out a portion, it is treated as a food.

This distinction is regulatory, not nutritional. The product itself is unchanged apart from the capsule shell, and in both cases, it is typically used with the same purpose: to supplement the diet with a rich source of fat-soluble nutrients. Yet, because of this format-based classification, the labelling requirements – and the expectations placed on the producer – can differ significantly.

This inconsistency can be confusing for consumers, who may assume that the labelling reflects fundamental differences in the product, when in fact it reflects only the packaging. It also highlights the challenge of applying rigid regulatory frameworks to traditional, nutrient-dense foods that do not fit neatly into modern categories of either food or supplement.