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Feature Articles
18 November 2025

Influencer advertising of food supplements

Author(s)

This article examines the issue of influencer-driven advertising in the German food supplement market from the perspective of German consumer protection organizations. It highlights regulatory gaps in consumer health protection related to misleading health claims, inadequate dosage controls, and unregulated online marketing practices. The article also demonstrates the need for strengthened consumer health protection through coordinated regulatory action at the European level.
 
Keywords – food supplements, influencer, health claims, consumer protection law
 
Introduction and background
The market for food supplements in Germany is growing rapidly. Social media has become a key distribution channel, where influencers with substantial followings create health-related content and market health products. From a consumer protection perspective, this development raises concerns, as influencers often operate in a legal gray area between freedom of expression and advertising. Studies of influencer advertising for food supplements in Germany and Europe show that influencers often do not disclose their advertising activities as required under EU consumer law. Research has also found that the requirements of the EU Health Claims Regulation, also known as Regulation (EC) No 1924/2006,1 are frequently ignored, and dosage recommendations communicated by influencers may significantly exceed scientifically recommended values. The current regulatory framework for consumer health protection regarding food supplements has not kept pace with these developments. As a result, consumers face health and financial risks, while the already overburdened and underfunded food control authorities in Germany are unable to carry out their inspection duties. A 2019 study found that one in three required food inspections in Germany is not carried out, mainly due to staff shortages at the responsible authorities.2
 
Advertising for food supplements often promises simple solutions to complex health problems. Survey data suggest that 77% of adults in Germany use food supplements,3 even though scientific studies show that the majority of the German population is well-supplied with nutrients.4 In a 2024 representative survey commissioned by the Federation of German Consumer Organisations5 (VZBV), more than half of respondents (54%) said they had purchased food supplements in the last six months. German consumer associations often encounter concerned consumers who are uncertain about their nutritional status after being exposed to exaggerated and misleading advertising claims.6 On platforms such as Instagram and TikTok, vitamins, powders, and pills are sometimes presented as indispensable for health, beauty, or performance. Influencers act as important multipliers, reaching a broad, mostly young audience with their content and messages.
 
Market overview: Food supplements and social media
The German food supplement market is growing steadily. In February 2025, sales of vitamins, minerals, herbs, and supplements in pharmacies, drugstores, supermarkets, and mail-order channels increased by 10% year-over-year, reaching €4.275 billion.7 About two-thirds were purchased by mail order, excluding direct sales and sales via social media. Alongside this expansion, social media marketing and influencer marketing are also growing.
 
Definition of influencer
Since the early 2000s, influencers have been defined as individuals who are multipliers, leveraging their strong presence and reputation on social media to promote products or lifestyles. Marketing done through or by influencers is referred to as influencer marketing.
 
Social media influencers combine the editorial content and advertising spaces, assuming roles traditionally associated with media organizations. They build influence over their audience in a manner similar to that of opinion leaders – through parasocial relationships. The trust in influencers is reinforced by various factors identified in the field of behavioral economics.8 Of particular note here is authority bias: the tendency to regard information from supposed experts as particularly credible. Due to influencers' perceived expert knowledge of products, such as food supplements, they appear particularly trustworthy and can therefore influence consumer purchasing decisions. The many followers who seem to trust and support the influencer's recommendations reinforce the perception of this influencer as credible and authentic.8
 
Unlike regulated media professions, influencers do not undergo any structured training. They do not face binding ethical, legal, or organizational regulations.9 Some influencers exploit this gap to conduct potentially unfair business practices, such as promoting unproven alternative health products and paid coaching services. While resources for influencer communications ethics exist, such as a white paper10 and a guide for labeling advertising posts on Instagram11 created by the German Centre for Protection against Unfair Competition, according to a 2024 report, few influencers reported adhering to them.12
 
A growing trend among influencers is providing so-called scientific education on health topics, including issues related to acne, weight, longevity, and women's health issues (a trending topic). 87% of content creators offer advice on dietary, medical, or psychological issues without having the appropriate training.13 Often, this knowledge is merely gleaned from reading, sometimes freely interpreted. It is challenging for consumers to distinguish between influencers who offer reliable information (despite the lack of professional qualifications) and those who primarily pursue commercial interests. The consumer is particularly at risk when the boundaries between authentic-seeming advice and pure marketing become blurred.
 
Influencer impact
Companies can leverage influencers’ credibility and targeted reach to promote food supplements. The global influencer marketing sector is projected to reach about $22.2 billion in 2025. In German-speaking countries (Germany, Austria, Switzerland), 79% of marketing managers surveyed reported that their companies budget more than €10,000 annually for influencer marketing, and the trend is growing.14 According to a 2023 consumer study, online shoppers and social media users in Germany purchased food/beverages (36%), beauty products (32%), or health and wellness products (28%) that were advertised by influencers.15 Unfortunately, it is not possible to more precisely classify the type of dietary supplements consumers are buying, as there can be discrepancies between consumer perception and product labeling.
 
Companies can leverage influencer advertising, which may have a broader reach than their own marketing efforts, to sell food supplements. A study by the German food safety authorities looked at company profiles and influencer profiles on social media. In terms of the number of followers, the company profiles mostly had only a few thousand followers, while the influencers had up to 600,000.16 A 2024 survey on the consumer behavior of young people in Germany revealed a particular openness to recommendations from influencers for this age group: 62% of girls and 47% of boys said they had bought a product recommended by an influencer.17
 
Influencer-driven advertising on social media also extends into sensitive health areas. Health and disease-related claims are used to promote products, often contrary to legal requirements, raising suspicions that influencers are driven by sales rather than genuine belief in the products. In fact, misinformation about nutrition on social media is a growing public health problem, especially since many public health institutions and health professionals fail to share evidence-based knowledge to counteract the influence of unreliable sources.18 A 2024 study19 comparing eight countries found the highest prevalence of health-related misinformation (described as “cherry-picked, exaggerated, and twisted”) on social media and YouTube in Europe, particularly in Germany. Among the topics surveyed, misinformation around food supplements ranked among the most common forms of health-related misinformation.
 
Legal framework
The Food Information Regulation (EU) 1169/201120 (LMIV) applies to all food companies and their advertisers, including online and social-media sales. According to Article 14, labeling requirements also apply to distance selling (i.e., sales from online shops and through social media). Article 7 sets requirements for fair information practices. The Health Claims Regulation (Regulation (EC) No. 1924/2006) regulates nutrition and health claims.1
 
In addition, the European Digital Services Act (DSA)21 applies. The DSA regulates the activities of digital service providers within the EU. It aims to ensure that online platforms handle content and products in a more responsible and transparent manner. It prohibits the trade of illegal goods, content, and services, and applies to all digital platforms, regardless of whether they are micro-enterprises or large companies. Special regulations also apply to very large online platforms and search engines (e.g., Amazon, Facebook, Instagram, LinkedIn, TikTok, X (formerly Twitter), and YouTube).
 
In addition to the established right to defend oneself against online platforms or other users, the DSA requires that these platforms offer mechanisms to report illegal content. An instrument for enforcing the regulations is the trusted flagger role. European national supervisory authorities (in Germany, the Federal Network Agency) appoint trusted flaggers (e.g., consumer organizations) based on specified requirements.
These trusted flagger alert platforms are used to identify potentially illegal content (e.g., content that violates consumer law). The social media platforms must review the reports and decide whether to delete the content. If a platform decides not to remove content, it must justify its decision. In June 2025, the umbrella organization of German consumer protection organizations, VZBV, was appointed as a trusted flagger.22
 
Within the DSA, children and young people are considered a particularly vulnerable target group. Article 28 of the DSA requires online platforms to implement measures to protect minors from risks such as manipulation and harmful content. Platforms that target minors must have enhanced protective measures, including a complete ban on targeted advertising. The DSA also mandates that online advertising be clearly labeled and include disclosure of who paid for the advertising.23
 
The VZBV presented a study on this topic in June 2025.24 The analysis of selected products on ten platforms and 30 product pages showed that the mandatory information that online marketplaces collect from retailers is not sufficiently accessible to consumers. As a result, consumers who want to buy a product from an online retailer outside the European Union may not receive the contact details for product safety concerns or product safety information, despite having a right to safe products, as reflected in Article 14 of Regulation (EC) 178/2002.25 When problems arise, affected consumers often have no point of contact. Consumers need to be able to contact a responsible party with the necessary skills and resources who is actually available and accessible. Strengthening platform liability will be needed to ensure marketplace operators assume greater responsibility for what happens on their platforms.24
 
Consumer protection perspective
Influencers rarely label advertising
In an EU-wide coordinated investigation,12 the Consumer Protection Cooperation Network reviewed the social media profiles of over 500 influencers. The participating authorities and associations wanted to determine whether influencer advertising on social media was sufficiently labeled. The review covered profiles on the major platforms: Instagram, TikTok, YouTube, Facebook, X, Snapchat, and Twitch. Of the influencers examined, 82 had over 1 million followers, 301 had 100,000–1 million followers, and 73 had 5,000–100,000 followers. The influencers reviewed were mainly active in the areas of fashion, lifestyle, beauty, nutrition and food, sports, and gaming. Key findings showed:
 
  • 97% regularly published content with the intention of making a profit;
  • Only about 20% of them consistently labeled content as advertising, which is considered misleading under Directive 2005/29/EC27 on unfair commercial practices;
  • 30% of profiles (173 accounts) lacked adequate legal notice in accordance with the European Digital Services Act;
  • 78% engaged in commercial activities, but only 36% were registered as food retailers at the national level;
    40% advertised their own products, services, or brands; and
  • Nearly two-thirds (60%) did not consistently disclose advertising.
 
Observations by German consumer associations show that food supplement influencers with up to approximately 25,000 followers often do not have their own websites. Their social media accounts also lack a reference to an Impressum, a legally required notice in Germany listing the responsible person or company and their contact information. Sales are made exclusively via direct messages and or WhatsApp groups. According to the Chemical and Veterinary Inspection Office Stuttgart (CVUA Stuttgart), consumers are sometimes provided with supposedly exclusive information and questionable consumption recommendations about food supplements in these chat groups or via private messages.26
 
In addition, some influencers (especially those on TikTok and Instagram) have developed their own coded language, known as “algospeak” or “leetspeak,” to prevent their posts on sensitive topics from being blocked by content moderation algorithms. Emojis, special characters, and numbers are used to obscure sensitive terms in content descriptions, subtitles, or thumbnails. For example, in German, “bull€mie” is used instead of “Bulimie” (bulimia), and in English, “ED” is used for eating disorders.28
 
TikTok recently blocked the hashtag #SkinnyTok, redirecting users to a page offering help for body dysmorphic disorders, following pressure from France and other EU countries.29 However, other related hashtags, such as #Skinny, #Slimtok, and #SkinnyTalk (the alternative in algospeak), remain unblocked. Similarly, trends such as sleepmaxxing, promoting optimized sleep, are currently trending,30 spreading potentially dangerous, unscientific tips, including the consumption of sleep-promoting drink powders and sleepmax gummy bears containing melatonin.31
 
Trusting influencers can pose health risks
When products fail to deliver the health outcomes they claim to, consumers may suffer financial harm. Additionally, these products can present significant consumer health risks.
 
Market checks by German consumer associations, along with findings from official food control authorities, show that the dosage of supplements promoted online and through influencers often exceeds the scientific recommendations established by the Federal Institute for Risk Assessment and the European Food Safety Authority (EFSA) for vitamin and mineral intake.32 These excessive dosages pose health risks for consumers.33,34 In addition, these products often contain exotic or isolated plant substances such as ashwagandha, monacolin K, curcumin, melatonin, or piperine, which can pose risks for certain population groups.
 
The VZBV and the German consumer associations are particularly critical of certain social media trends. For example, the phenomenon of “melatonin moms” on TikTok and Instagram involves stressed parents promoting food supplements containing melatonin as sleep aids for young children. Medical associations caution that melatonin should only be administered under medical supervision and at the lowest effective dosage, citing reports of several deaths of young children in the US that have been associated with melatonin overdoses.31,35
 
However, many influencers deny any risks and even encourage consumption beyond recommended intake levels stated on the product packaging. Food supplements marketed for specific health conditions may lead consumers to forgo seeking medical advice and instead rely on influencer testimonials, rather than consulting a doctor. The VZBV and German consumer associations emphasize that risks increase when necessary medical treatment is not sought or when adverse interactions or side effects occur when medications and food supplements are taken in parallel.36
 
Influencer compliance with the Health Claims Regulation
Food supplements advertised by influencers and manufacturers that promote unauthorized and misleading health and disease-related claims continue to appear on the market. The Stuttgart food control authority launched two major investigations into this issue. The first project,16 published in 2022, examined almost 5,000 posts containing nearly 1,000 health claims from 38 food supplement companies in Baden-Württemberg. It found that 39% of the health claims were classified as not allowed. The majority of these (67%) appeared only on Instagram and not in companies’ online shops. However, when influencers advertised these same products, around 90% of the health claims were classified as inadmissible. Overall, among the project samples actively promoted through social media and influencer advertising, the complaint rate by the food authority was 85%. The study authors emphasized that food control authorities should pay closer attention to the rate of inadmissible health claims, particularly due to the sometimes significant reach of influencers.
 
A follow-up project published in 202526 showed that influencers and companies often promise that nonspecific symptoms can be alleviated by taking high-dose vitamin supplements, special plant extracts, or detox treatments. In online chat groups or via private messages, allegedly exclusive information and questionable consumption recommendations about food supplements are relayed directly to consumers. Market observations and experiences of German consumer associations show that promotional videos on platforms such as YouTube often contain exaggerated health claims that appear to be backed up by scientific studies. Furthermore, according to the study, it is often difficult for social media users to distinguish genuine influencer recommendations from paid advertising.
                                                     
In August 2025, Foodwatch, a German consumer protection organization, published a report analyzing Instagram posts by 95 health and fitness influencers over a 20-day period. Among data collected from 358 Instagram stories advertising 152 different food supplements, around one-third contained health claims, all of which Foodwatch classified as inadmissible.37 Additionally, cross-border investigations by the European Commission revealed that many high-reach influencers did not label product advertising as such.38 In a position paper, the VZBV criticized the fact that supposed testimonials from influencers could not be verified by consumers.39
 
Legal action
The European Union is working to ensure that influencers comply with media law requirements through controls and information services such as the Influencer Legal Hub.40 However, member states are responsible for ensuring influencer compliance regarding food laws, particularly the Health Claims Regulation.
 

Areas of responsibility

In Germany, food control authorities are responsible for ensuring that food companies comply with food law regulations. However, they are not responsible for regulating questionable statements made by influencers. Companies that are active on social media remain responsible for the content on their own channels. Influencers typically work in cooperation with companies and receive compensation for their advertising in the form of monetary payments or products. As a result, influencers serve as the advertising face of a company, engage in dialogue with them, and increase product sales through their advertising efforts. However, if a paid advertising partnership exists between an influencer and the company, the advertising statements made by the influencer can be legally attributed to the food business operator, and therefore fall under the same regulatory obligations as company-originated claims.26 Proving that an advertising partnership exists, however, can pose a problem for food control authorities.
 
In the case of influencers launching their own products on the market, they are no longer only advertising figures but are also legally responsible for compliance with food law. All statements they make on social media about their own products are attributed to them as the responsible person. From the authors' perspective, these statements ultimately serve the purpose of advertising and increasing sales.
 
The difficulty of social media monitoring
In Germany, under-resourced food control authorities are overwhelmed when it comes to monitoring influencer advertising on social media, given the rapid pace and high volume of posts. The VZBV and German consumer associations have been advocating for increased funding and staffing for years, but so far, the urgently needed political reforms have not happened.
 
Practical enforcement obstacles compound these resource limitations. Authorities often have limited or no access to social media platforms and face difficulties when attempting to make online purchases (for the purposes of an anonymous sampling or payment). Additionally, there can be unclear responsibilities among state media authorities and food control authorities in handling complaints. This confusion results in complaints being transferred between state media authorities, district offices, and health departments, sometimes resulting in delays due to technical access barriers or restrictive data-sharing rules. When the authorities do act, German consumer associations report that they often do not disclose whether an enforcement action has taken place, citing data protection constraints.
 
Additionally, complaints can sometimes take years to process, allowing influencers to continue selling their products without consequence. Reports made directly to the platforms are typically ineffective. Sometimes, the platform’s algorithm mistakenly suspends the complainant’s account for spreading “illegal content,” necessitating human review before account reactivation.
 
Additionally, staff shortages (e.g., local municipal authorities), a lack of digital equipment, and difficulty locating influencers can pose challenges for food control authorities. Influencers regularly relocate their official residence to well-known PO box addresses (often in Dubai) or foreign countries to avoid taxation.
 
In contrast, when financial interests are involved, such as tax revenue, government authorities appear to act much more quickly. The State Office for Combating Financial Crime is currently conducting around 200 criminal proceedings against influencers living in North Rhine-Westphalia for alleged tax evasion. An additional 6,000 cases are also under review in the North Rhine-Westphalia area. These cases require the investigators to conduct a continuous, comprehensive analysis of social media activities to determine the actual place of residence. Only then are search warrants and arrest warrants possible. Many influencers purposely obscure their location to evade taxation. The fact that social media tax evaders act deliberately is also evident in a disproportionately high proportion of repeat offenders.41
 
Recommendations
From the perspective of the VZBV and German consumer associations, the current legal classification of these products as foodstuffs does not meet the requirements of consumer health protection, as they often contain highly concentrated vitamins, minerals, or plant substances that can have pharmacological effects. This distinguishes them significantly from conventional foods, for which the regulations were originally intended. Consumer studies commissioned by the VZBV show that consumers take food supplements on the assumption that they have been tested and are effective in a manner similar to medicines.42 However, foodstuffs are not subject to any official safety, quality, or efficacy testing before being placed on the market. There are no binding maximum levels of vitamins and minerals, no positive lists for ingredients, and side effects are not systematically recorded. Additionally, classification as a foodstuff can lead to inadequate market surveillance, particularly online, where misleading health claims are prevalent. From the VZBV's and the German consumer associations' point of view, stricter regulatory requirements are therefore necessary.

 As marketing via social media and influencers increases, consumers are exposed to more instances of misleading health claims and questionable dosage recommendations.
 
A systematic review and adjustment of the regulatory framework is therefore recommended to effectively ensure consumer health protection. Key recommendations of the VZBV and German consumer organizations include:36
 
  • Establish a premarket authorization process for food supplements at the EU level;
  • Introduce European-wide maximum levels for vitamins and minerals in food supplements, differentiated by age group, particularly with respect to children;
  • Create a legally binding positive list of other substances (e.g., botanicals) permitted for use in food supplements, with clear criteria for inclusion;
  • Complete pending EFSA assessments of plant-based health claims (on-hold claims), after which it will be necessary to establish regulation at the European level based on those assessments;
  • Establish reporting offices to systematically record the side effects and interactions associated with food supplements at a national level;
  • Increasing scrutiny by food control authorities of the online market for food supplements, including the distribution and advertising of food supplements on social media; and
  • Prohibit influencer advertising for children's food supplements, thereby improving consumer protection for this particularly vulnerable group.
 
From the perspective of the VZBV and the German consumer associations, implementing these measures would improve consumer health protection and standardize market conditions across the EU, benefiting both consumers and manufacturers.
 
Conclusion
Influencers are playing an increasingly significant role in the food supplement market, influencing consumers' purchasing decisions. From a consumer protection perspective, this poses several problems, including the high number of health claim violations made by influencers. Given the dynamics of online commerce, the responsible supervisory authorities are structurally overwhelmed, which has largely prevented effective enforcement of the law to date. In this context, the VZBV and the German consumer associations are calling for food monitoring authorities to pay closer attention to influencer marketing for food supplements. Comprehensive adjustments to the European legal framework for food supplements and structural improvements in food control are necessary to improve consumer health protection, in particular, an authorization procedure for food supplements prior to marketing, more resources for the control authorities, and a ban on influencer advertising for children's food supplements.

Abbreviations
DSA, Digital Services Act; VZBV, Federation of German Consumer Organisations

About the authors
Angela Clausen, Dipl Oec troph, is a nutritionist and works as a scientific adviser at the Consumer Association North Rhine-Westphalia, Düsseldorf. For more than 20 years, she has specialized in foods marketed for health and wellness, focusing primarily on food supplements, health claims, and distribution channels. She can be reached at [email protected]
 
Sabrina Göddertz, MA, has been a policy officer at the Federation of German Consumer Organisations, Berlin, for five years. She works on the VZBV's food team on issues relating to food safety, labeling, and supplements. She can be reached at [email protected]
 
Citation Clausen A, Göddertz S. Influencer advertising of food supplements. Regulatory Focus. Published online 17 November 2025. https://www.raps.org/news-and-articles/News-Articles/2025/11/Influencer-advertising-of-food-supplements
 
References
All references were last checked and verified on 14 November 2025.
 
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