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Proprietary Blends: A Plain Guide

A legal disclosure that tells you one number and eight names. Here is everything you can still extract from it, and the point where the trail goes cold.

Quick answer

A proprietary blend is a group of dietary ingredients declared on a Supplement Facts panel as a single combined weight rather than individually. Under 21 CFR 101.36(c) the label must give the total weight of all the dietary ingredients in the blend, and must list those ingredients in descending order of predominance by weight. Individual amounts are not required. That means you can read the order and the total, and nothing else.

What the rule actually says

The relevant text is 21 CFR 101.36(c), part of the federal regulation governing the nutrition labeling of dietary supplements. It is short and it is worth knowing in the original rather than in a summary.

It permits dietary ingredients that are not required to be declared individually to be listed under a collective name, with the total weight of all of them given as a single figure, provided they are listed in descending order of predominance by weight.

Two obligations, then. Print the total. Print the members in weight order. That is the whole disclosure requirement, and a label that does both is fully compliant no matter how uninformative the result is.

The rule exists for a defensible reason. A company that develops a formula has a commercial interest in not publishing the recipe for a competitor to copy, and that interest is real. The side effect is that the buyer cannot evaluate the product either, and the buyer is the one paying.

The compliance point, stated once

A proprietary blend is not a trick, a loophole or a violation. It is a legal labelling choice, used by a very large share of this category. The criticism on this site is of the choice, not of the legality, and it applies to every label that makes it.

What you can still work out from a blended panel

More than people assume, and less than you need. Four things survive.

First, the ceiling. No single ingredient can exceed the blend total. If a blend is 500 mg and one of its members has a research dose of 600 mg, that dose is impossible and you know it for certain. This is the most powerful move available to a reader of a blended label, and it costs nothing.

Second, the order. Descending by weight is a genuine constraint. The first name weighs at least as much as the second, which weighs at least as much as the third. On a long blend this tells you a great deal about where the money went.

Third, the floor by implication. If a blend has eight members and totals 1,200 mg, the last member cannot be more than 150 mg, because if it were, the seven above it would each be at least that too and the total would exceed the declared figure. The same logic gives you a maximum for every position in the list.

Fourth, what is not in the blend. Ingredients printed above the blend line, with their own amounts, are disclosed normally. A label that discloses two ingredients individually and hides six has told you which two it is proud of.

The two calculations that settle most blended labels

Both take under a minute, and between them they resolve most of the question.

Worked on a hypothetical eight-ingredient, 1,200 mg blend.
The calculationHow to do itWhat it tells you
The ceiling testTake the blend total. Compare it against the research dose of each named ingredient, one at a time.Whether a given dose is even arithmetically possible. If the blend total is below a single ingredient's studied dose, no amount of marketing changes that.
The position maximumDivide the total by the ingredient's position in the list. For the 4th of eight in a 1,200 mg blend: 1,200 ÷ 4 = 300 mg.A hard maximum for that ingredient. It cannot exceed this, because the three above it are each at least as large.
The even-split averageDivide the total by the number of members. 1,200 ÷ 8 = 150 mg.Not a real amount, and a useful order of magnitude to hold in your head while reading research doses.
The last-place maximumThe position maximum applied to the final member.The most revealing single figure on many blended labels, because it is usually far below anything with evidence behind it.

Notice what none of these produces: an actual amount. Every one of them is an upper bound. You can prove a dose impossible and you can never prove one adequate, and that asymmetry is the whole practical consequence of the rule.

Why blends hide weak ingredients rather than strong ones

This is the part that decides how much suspicion a blend deserves, and it comes down to incentives rather than chemistry.

A company that has put a research-grade dose of an expensive ingredient into a product has spent money on it, and the printed amount is the evidence of that spending. Printing it is free marketing. There is no commercial reason to hide a number you paid for.

The reverse is also true. An ingredient present in a token amount, purely so that its name can appear on the front of the bottle, is one whose amount undermines the marketing. Hiding it is the only way to keep the name and lose the number.

So the expected direction of a blend's information asymmetry is one-way. When amounts are hidden, the reasonable prior is that some of them are small, because the small ones are what hiding protects.

This is an inference about incentives, not a finding about any particular product. Plenty of well-dosed formulas sit inside blends for perfectly ordinary competitive reasons. The point is that you cannot distinguish the two from the outside, and the burden of that uncertainty falls on the person paying.

The question to ask a brand

Ask for the breakdown. A company confident in its doses can publish them in an email in five minutes without changing its label. A company that declines has told you something, and a company that replies with the blend total again has told you more.

Six checks for any blended label

Run these in order on any product with a proprietary blend on the panel. They apply just as much to the one this site sells.

1

Count the members

The more names in a blend, the less each one can weigh. A 500 mg blend with twelve ingredients is a list of names rather than a formula.

2

Find the first name

It weighs the most, and it is very often the cheapest bulk material in the list. Look up what it costs per kilogram and the picture usually clarifies.

3

Run the ceiling test

Compare the total against the largest research dose among the members. If the total loses, the label has told you something important for free.

4

Look for standardisation

A blend that also omits standardisation percentages is doubly opaque, because even a published amount would not be comparable to a trial.

5

Check what sits outside the blend

Individually disclosed ingredients are the ones the brand wants you to be able to check. Their absence is itself informative.

6

Ask for the breakdown

In writing, before you buy the six-pack. The reply, or the absence of one, is data.

How this applies to the product on this site

Horse Honey declares one Test Boost Proprietary Blend of 1,200 mg containing eight ingredients, with no individual amounts and no standardisation percentages. The even-split average is 150 mg. The last-place maximum is also 150 mg. The one ingredient here with a placebo-controlled trial, tongkat ali, used 200 mg a day of standardised extract in that trial, and sits second of eight. Whether it reaches that dose here is exactly the thing the label does not say.

About the product behind this blog

Horse Honey Advanced Formula is a men’s performance capsule: eight ingredients sharing one 1,200 mg Test Boost Proprietary Blend, with no individual amounts published. We print the arithmetic the label leaves out.

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The one question that resolves most of this

Ask the brand, in writing, for the breakdown of the blend. A company confident in its doses can send it in five minutes without changing a thing on its label, because the information already exists in the specification sheet the formula was made from. A company that declines has told you something. A company that replies with the blend total again has told you more.

Where the convention came from

Proprietary blends are not an old practice. They arrived with the Supplement Facts panel itself, which the FDA introduced in the late 1990s following the Dietary Supplement Health and Education Act, and the blend provision was written into the labelling rule from the start.

The argument made for it at the time was trade secrecy, and it was not a bad argument. A small company that develops a formula has no patent protection over a combination of ordinary botanicals, and publishing the exact ratios hands the recipe to anybody with a contract manufacturer.

What happened afterwards is that the provision became a default rather than an exception. In several categories, including this one, a blended panel is now more common than a fully disclosed one, and the trade-secret justification covers formulas that are sold by the same contract manufacturer to a dozen different brands.

That is the honest criticism of the convention. Not that it exists, but that it is now used by products whose formulas are not secret from anybody except the person buying them.

Horse Honey Advanced Formula · 60 capsules1 or 2 capsules daily · 1,200 mg blend · price shown at checkout
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