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Latest News · October 22, 2026 · 7 min read

FDA Final NDI Guidance: Why 25 Years of Safe Use Matters

FDA's final guidance (Oct 19, 2026) tells supplement makers what identity and safety data new dietary ingredient notices need, incl. a 25-year use benchmark.

By Chris Carrillo · Reviewed by Armin Rad, Co-Founder & CTO, Aurascan · October 22, 2026

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Illustration of a scatter of softgel capsules beside a small brass kitchen scale

FDA announced final guidance on identity and safety information for new dietary ingredient (NDI) notifications on October 19, 2026, and the Federal Register published the notice of availability on October 20, 2026 (91 FR 66336, Docket No. FDA-2025-D-6501). The guidance is nonbinding and finalizes three sections of FDA's 2016 revised draft, replacing the 'comprehensive safety profile' with a single 'safety narrative' for all NDINs. It sets no compliance date.

Key takeaways

  • FDA announced the final guidance on October 19, 2026, and the Federal Register notice published October 20, 2026.
  • The guidance is nonbinding, runs 53 pages, and finalizes Sections VI.A, VI.B and VI.C of the 2016 revised draft.
  • An NDI notification (NDIN) is due at least 75 days before an NDI-containing supplement enters interstate commerce.
  • FDA calls the NDIN process its only opportunity to evaluate NDI safety before supplements reach consumers.
  • No compliance date was disclosed.

What happened

On October 19, 2026, FDA announced a final guidance for industry titled 'New Dietary Ingredient (NDI) Notifications and Related Issues; Identity and Safety Information About the NDI.' The announcement came through FDA's Human Foods Program and points readers to the guidance document and its public docket.

The formal notice of availability was published in the Federal Register on October 20, 2026, as 91 FR 66336 (FR Doc. 2026-21453) under Docket No. FDA-2025-D-6501. The guidance runs 53 pages and is dated October 2026.

FDA frames the stakes in one sentence: the NDIN process is 'the agency's only opportunity to evaluate the safety of NDIs in dietary supplements before they become available to consumers.' That framing is the main reason the guidance matters to anyone buying supplements that contain newer ingredients.

What changed

The guidance finalizes Sections VI.A (Identity Information about the NDI and the Dietary Supplement), VI.B (History of Use or Other Evidence of Safety) and VI.C (Summary of the Basis for Your Conclusion of Safety) of FDA's 2016 revised draft. The most visible change is terminology. FDA removed references to a 'comprehensive safety profile' and now recommends a single 'safety narrative' for all NDINs.

The final text is written in question-and-answer format. The guidance also adds clarity on what the narrative should include, when additional evidence of safety should be submitted, and which types of studies are recommended. According to FDA's document, the safety narrative should estimate total daily human intake and describe any potential toxicity or health concerns, particularly for vulnerable populations. FDA says it continues to prioritize finalizing other parts of the 2016 revised draft, and no timeline for those parts was disclosed.

What is a new dietary ingredient notification?

An NDI notification (NDIN) is the submission described in section 413(a)(2) of the FD&C Act, and it must be submitted at least 75 days before the product is introduced into interstate commerce. The manufacturer or distributor of an NDI, or of a supplement containing it, must submit the NDIN to FDA. The submission must include information supporting the conclusion that the product will reasonably be expected to be safe (21 CFR 190.6).

Does FDA approve supplements before they are sold?

FDA calls the NDIN process its only opportunity to evaluate NDI safety before supplements reach consumers. The cited sources do not describe a general pre-market approval for all supplements. For NDIs, the quality and completeness of the safety information a company submits is therefore central to that review.

Does the guidance require human clinical studies?

The FD&C Act does not expressly require human clinical studies before an NDIN, though FDA may recommend them when other data are insufficient. The guidance also explains how safety margins work. The margin of safety is the no-observed-adverse-effect level (NOAEL) divided by the estimated daily intake (EDI). A 100-fold margin means no-adverse-effect doses are 100 times the intake from the supplement.

A combined safety factor of 100 is usual for chronic (one-year or longer) animal studies. A factor of 1,000 applies when extrapolating from two subchronic (90-day) studies, one in a rodent and one in a non-rodent species. Relying on a single rodent subchronic study is 'strongly discouraged,' but it might be acceptable with a safety factor of 2,000.

Who is affected

The guidance is aimed at companies that manufacture or distribute NDIs and supplements containing them. It concerns dietary supplements, not food or cosmetic ingredients. The sources do not identify which specific ingredients or products prompted the guidance, and FDA's materials do not say how many NDINs the agency receives or objects to each year.

Scope depends on whether an ingredient is an NDI. The guidance states that ingredients marketed in the United States before October 15, 1994 are not NDIs and do not require an NDIN.

What counts as a new dietary ingredient?

An NDI is a dietary ingredient that was not marketed in the United States before October 15, 1994. Ingredients marketed before that date are not NDIs.

Do botanical ingredients have special identity rules?

Yes. For botanicals, FDA recommends identifying toxins known in the same species or in a phylogenetically related family or genus, and documenting their absence or amount in the NDI. The recommendation also covers the analytical procedures, data and calculations behind that documentation.

What it means for shoppers

The guidance is nonbinding. In its own words, it 'does not establish any rights for any person and is not binding on FDA or the public.' It is not a label rule that a shopper can check on a package, and the sources do not say that an NDIN number or safety narrative will appear on a product. Shoppers should not expect to find an NDIN number on the Supplement Facts panel.

The guidance does give shoppers a few concrete points to keep in mind when reading a supplement label, each tied to the sourced framework:

  • Identity information is the focus of Section VI.A, so the full name and form of each ingredient matters when comparing products.
  • FDA's safety narrative estimates total daily intake, so compare the amount listed per serving with the stated serving size.
  • For botanicals, FDA's identity recommendations are built around species and related plants, so note whether the label identifies the species.

How long does history of safe use need to be?

FDA generally recommends 25 years of widespread use as the minimum to establish a history of safe use when that history is the only basis for safety. FDA also says the number of consumers and the frequency of intake are at least as important as the number of years.

Are vulnerable populations addressed?

The safety narrative should describe potential toxicity or health concerns, particularly for vulnerable populations. The sources do not list which populations FDA has in mind for any given ingredient, and they do not provide product-level findings. Shoppers should not infer from the guidance alone that a product is suitable or unsuitable for any group. People who are pregnant or nursing, take medicines, or manage a health condition may want to ask a qualified clinician before using a supplement.

The background

FDA announced a draft NDI guidance on July 5, 2011 (76 FR 39111), with comments due October 3, 2011. After receiving significant comments, FDA issued a revised draft on August 12, 2016 (81 FR 53486). The comment period on the revised draft was extended to December 12, 2016 (81 FR 68434). Ingredients added to conventional foods follow a separate premarket path, GRAS, which FDA has separately proposed to tighten (FDA Proposes Ending Self-Affirmed GRAS: What Changes for You).

The final guidance comes from that process. It covers three sections of the 2016 revised draft and is not a full replacement for that document, because FDA says other parts are still being prioritized for finalization.

The framework is already in use. In a warning letter posted October 20, FDA treated Amanita muscaria and its constituents as new dietary ingredients and found three supplements adulterated; the company had filed NDI notification #1417 in 2025 (FDA Warns Amanita Muscaria Brand: Calm, Calmer and Santa Adulterated).

What to watch next

No compliance date is set in the final guidance, so no deadline for industry action has been announced in these sources. FDA says it continues to prioritize finalizing the other parts of the 2016 revised draft, but the timing of those remaining sections was not disclosed.

Comments may be submitted at any time to Regulations.gov under docket FDA-2025-D-6501. Industry reaction is not covered in the FDA or Federal Register materials cited here, so this article does not report any.

These sources describe what FDA recommends for submissions and how it frames its review. They cannot establish how any individual will respond to a given ingredient, what happens in populations that have not been studied, or how open research questions about ingredient safety will be resolved. Treat the guidance as a description of the review framework, not as a verdict on any product.

If you want to see how an ingredient list reads in practice, you can scan a product with the Aurascan app, which explains each ingredient one by one with cited evidence.

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Common questions

What is a new dietary ingredient notification?
An NDI notification (NDIN) is the submission described in section 413(a)(2) of the FD&C Act. The manufacturer or distributor must submit it to FDA at least 75 days before introducing an NDI-containing supplement into interstate commerce, with information supporting the conclusion that the product will reasonably be expected to be safe (21 CFR 190.6).
Does FDA approve supplements before they are sold?
FDA calls the NDIN process its only opportunity to evaluate NDI safety before supplements reach consumers. The cited sources do not describe a general pre-market approval for all supplements.
What is an NDI?
An NDI is a dietary ingredient that was not marketed in the United States before October 15, 1994. Ingredients marketed before that date are not NDIs and do not require an NDIN.
How long does a history of safe use need to be?
FDA generally recommends 25 years of widespread use as the minimum when that history is the only basis for safety. FDA says the number of consumers and frequency of intake are at least as important as the number of years.
Is the FDA's NDI identity and safety guidance binding?
No. The guidance states that it does not establish any rights for any person and is not binding on FDA or the public.
Does the guidance set a compliance date?
No. The guidance sets no compliance date, and no compliance date was disclosed. FDA has also not disclosed when the remaining parts of the 2016 revised draft will be finalized.

Sources

  1. FDA Issues Guidance on Identity and Safety Information for New Dietary Ingredient Notifications (fda.gov)
  2. Guidance for Industry: New Dietary Ingredient (NDI) Notifications and Related Issues; Identity and Safety Information About the NDI (fda.gov)
  3. New Dietary Ingredient (NDI) Notifications and Related Issues; Identity and Safety Information About the NDI (guidance PDF) (fda.gov)
  4. New Dietary Ingredient (NDI) Notifications and Related Issues; Identity and Safety Information About the NDI; Guidance for Industry; Availability (federalregister.gov)

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