Veterinary medicine or supplement? The difference

Two separate legal categories

In the Netherlands and the EU, products for animals fall into two strictly separated legal categories: veterinary medicinal products and supplements (also known as food supplements or feed materials for animals). The difference has major consequences for what manufacturers may claim, how a product is controlled and who may administer or prescribe it.

What is a veterinary medicinal product?

A veterinary medicinal product is a substance or combination of substances intended to prevent, diagnose or treat a disease in animals [4]. EU Regulation 2019/6 applies two criteria which together determine whether something is a medicinal product:

• Claim criterion: the product is presented as a means to treat or prevent diseases.
• Pharmacological criterion: the product has a pharmacological, immunological or metabolic action.

If either of the two criteria is met, then a product is legally a veterinary medicinal product and full registration obligation applies [4][5]. Manufacturers must then demonstrate via the Medicines Evaluation Board (College ter Beoordeling van Geneesmiddelen, CBG) or the EMA that the product is effective and safe before it may be placed on the market.

What is a supplement?

Supplements for animals fall under feed materials legislation, not under medicinal products legislation. They are intended as a supplement to normal nutrition — think of vitamins, minerals, herbs or amino acids — but must make no medical claims.

The consequence: manufacturers of supplements do not have to demonstrate efficacy for market authorisation. The government checks for safety and fair labelling, but not for effect [5]. This explains why supplements are generally cheaper, but also why quality can vary greatly. Research into herbal supplements shows that contamination with heavy metals is a real quality problem — also for products offered as 'natural' [2][3].

The grey area

In practice, there is a considerable grey area. A manufacturer who wishes to sell their product as a supplement must strictly avoid medical claims — even subtle formulations such as 'supports healthy joints in case of inflammation sensitivity' can already be regarded as a disguised medicinal product claim [4][5].

This sometimes leads to remarkable situations. A substance such as CBD is sold as a supplement in many EU countries, but the scientific substantiation for it belongs to the domain of medicinal product research [1]. Whether a product is a supplement or a medicinal product depends in such cases on the way it is presented — the NVWA (Netherlands Food and Consumer Product Safety Authority) can intervene if the claim limit is exceeded [5].

Comparison table

What does this mean for you as an animal owner?

A supplement is not by definition safer or more effective than a registered veterinary medicinal product — it is regulated differently. Are you considering a supplement alongside regular medication, or do you doubt whether a product is suitable for your animal? Always discuss this with a veterinary surgeon. Tailored treatment advice is legally reserved to veterinary surgeons in the Netherlands.