Proprietary blends
The legal mechanism that lets one number stand in for eight, and what a reader can still recover from it.
A proprietary blend is a group of dietary ingredients declared as a single total. 21 CFR 101.36(c) permits it: the blend gets a name, a total weight and a list of its contents in descending order of predominance by weight, and the individual amounts may be omitted.
Three things must still be true, and all three are usable. The total must be accurate. The order must be descending by weight. And every ingredient must be named.
What the regulation actually permits
The rule is narrower than it is usually described. A blend is not a license to be vague; it is a license to omit one specific class of fact.
| Requirement | Blend? |
|---|---|
| The blend must be given a name | Required |
| The total weight of the blend must be declared | Required |
| Every dietary ingredient in it must be named | Required |
| Those names must be in descending order of predominance by weight | Required |
| The individual weight of each ingredient | May be omitted. This is the entire concession |
| A %DV where one exists for a listed nutrient | Still required for the nutrients that have one |
| A standardization ratio or marker compound | Not required for a blend or outside one. Sellers who give it are volunteering |
Scroll this table sideways →
So the blend hides one thing: the split. Everything else on the panel is as binding as it would be on any other label, which is why the order can be used as evidence rather than treated as presentation.
Why blends exist
It is worth putting the case for blends properly before taking it apart, because the case is not empty.
Formulation is real work
Choosing eight ingredients and their ratios takes time, testing and money. Printing the ratios hands that work to any competitor with a bottle and a scanner, and there is no patent protecting a ratio of botanicals.
The alternative is not always better
A label that must print every amount tends toward fewer ingredients, and a formulator who believes a small amount of something contributes has a genuine incentive to leave it out rather than have it read as filler.
Supply chains move
Botanical extract potency varies by harvest and by supplier. A declared total can be held constant while the composition is adjusted; declared individual amounts cannot.
Those are real. They are also, all three, arguments for withholding the ratios — and none of them is an argument for withholding the ratios and the standardization and the elemental content of a mineral chelate, which is what a reader of this particular label is left with.
What a blend costs the buyer
The seller keeps the formulation private. Here is the specific list of things the buyer gives up in exchange.
- You cannot check a dose. Not against a trial, not against a competitor, not against the same product last year.
- You cannot compare on price sensibly. Cost per gram of blend is computable; cost per unit of anything you care about is not.
- You cannot assess an interaction. A pharmacist asked whether saw palmetto here matters alongside finasteride cannot answer without an amount.
- You cannot detect a reformulation. The total can stay at 1,200 mg while everything underneath it changes.
- You cannot tell filler from formula. An ingredient present at 5 mg and an ingredient present at 500 mg look identical on the panel.
That last one is the reason blends have the reputation they have. A long ingredient list is a marketing asset, and a blend lets a seller have the list without the cost of the ingredients. Nothing on this page establishes that SodaPeak is doing that, and nothing on the panel would let anyone establish that it is not.
Three questions to ask of any blend
How many names share the total?
Divide the total by the count for the average. SodaPeak: 1,200 mg over eight names is 150 mg each. If the average is already below the studied dose of most of the list, the arithmetic is finished before it starts.
What is in the last position?
The final ingredient has the smallest ceiling — the total divided by the count. It is the position where a ceiling is most likely to bite, and the one sellers rarely think of as load-bearing. SodaPeak’s eighth position has a ceiling of 150 mg.
Does any position force a contradiction?
Work from both ends. A large studied dose high in the list eats the budget for everything below it; a nontrivial dose low in the list forces a floor under everything above it. Where the two meet, you have a result that needs no further information.
That third step is what produced the only proof on this site. It is not a common outcome — most blends simply leave you with a set of ceilings and no contradiction — but it costs nothing to check.
Worked on this label
Running the three questions on the panel in front of us.
- How many names share the total?
- Eight share 1,200 mg, for an average of 150 mg. Two of the four ingredients with a studied dose need more than that average on their own.
- What is in the last position?
- Boron amino acid chelate, ceiling 150 mg, against a studied dose needing about 60 mg of chelate. Its position allows it — and forces at least 60 mg into every position above it, which is where the trouble starts.
- Does any position force a contradiction?
- Yes. Saw palmetto at position three and boron at position eight cannot both be at a studied dose. Separately, nettle root at position four has a ceiling of 300 mg against a studied dose of 360 mg, so it fails on its own without reference to anything else.
What a seller could disclose and lose nothing
Criticism that does not name a remedy is just complaining. There are four things this label could add without publishing the split at all.
The standardization of each extract
“Standardized to 10% icariin” tells a reader what kind of material is in there without revealing how much. Sellers who have paid for a standardized extract usually want to say so.
The elemental content of the mineral
A boron chelate’s elemental percentage is not a formulation secret. Publishing it would make the one mineral on this panel assessable and would give away nothing about the other seven positions.
A floor rather than an amount
“Contains at least 100 mg of tongkat ali” discloses less than an exact figure and is enough for a reader to check a dose against a trial. Nothing in the regulation forbids a voluntary minimum.
A certificate of analysis on request
Identity and potency testing on a finished lot, with the lab named and the date printed. The lot reference on this bottle is SOD-26/SO-1425, which is a draft label reference rather than a test result.
Any one of those four would move this product’s dose transparency score off the floor. None of them requires the seller to hand a competitor the formula.
The legal frame around all of this
Nothing on this page or this site alleges that SodaPeak is mislabeled. Declaring a proprietary blend is expressly permitted, and the panel does the four things the regulation asks of one.
Two separate labeling points on this product are worth distinguishing from the blend itself, because they would matter on any label: the footnote symbol does not match the blend’s, and the distributor line carries a name with no place of business. Both are recorded on the panel page.
And a general point about the category, which is context rather than a claim about this product: FDA has repeatedly found hidden prescription drug ingredients in supplements marketed as testosterone boosters, and FTC has taken action over testosterone-related advertising claims. Both are cited below. Neither concerns this product.
References
The sources behind the numbers on this page.
- U.S. Government Publishing Office21 CFR 101.36 — Nutrition labeling of dietary supplements, including the proprietary blend and descending-order requirements — Code of Federal Regulations · source
- U.S. Government Publishing Office21 CFR 101.5 — Food; name and place of business of the manufacturer, packer, or distributor — eCFR.gov · source
- U.S. Government Publishing Office21 CFR 101.93 — Certain types of statements for dietary supplements — Code of Federal Regulations · source
- U.S. Food and Drug AdministrationQuestions and Answers on Dietary Supplements — FDA.gov · source
- U.S. Food and Drug Administration — 2023T XTRA Strength Test Booster contains hidden drug ingredient — FDA.gov · source
- U.S. Federal Trade Commission — 1999Androgen Supplement Marketers Settle FTC Charges — FTC.gov · source
- NIH Office of Dietary SupplementsBoron — Health Professional Fact Sheet — ods.od.nih.gov · source
See the SodaPeak packs
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Shipping and the guarantee term are shown at checkout. This site publishes no number it was not able to verify.