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Proprietary blends, and what they hide

A proprietary blend is a legal label format, not a trick. It is also the single biggest reason a buyer cannot compare two supplements, and the Cognizil panel is a good place to learn to read one.

Last updated September 22, 2026By Cognizil Editorial Desk

21 CFR 101.36(c)

The rule, in one paragraph

Quick answer

A manufacturer may group two or more dietary ingredients under a made-up name, declare the total weight of the group, and list the ingredients inside it in descending order of predominance by weight without giving any individual weight. Cognizil declares 15.47 mg across 21 ingredients.

The regulation is 21 CFR 101.36(c). It exists so that a formulator who has spent money arriving at a particular ratio is not required to publish that ratio for a competitor to copy. That is a real commercial interest and the rule is not unreasonable on its face.

What the rule does not anticipate is a blend of twenty-one ingredients totalling fifteen milligrams. At that point the protected trade secret is not a ratio anyone would want to copy; it is the fact that there is almost nothing there.

The one lever

What descending order gives you

The order is not decoration. It is a guarantee, and it is the only quantitative information a blend declaration carries.

If the ingredients are listed heaviest first, then the first is at least as heavy as the second, the second at least as heavy as the third, and so on. Combine that with the total and a hard ceiling drops out of it: the ingredient in position k can weigh no more than the total divided by k.

Why that is true

If the first k ingredients are each at least as heavy as the k-th, then those k ingredients together weigh at least k times the k-th. They cannot weigh more than the whole blend. So k times the k-th is at most the total, which means the k-th is at most the total divided by k. It holds for every position, and it needs no information the label withholds.

On this label that turns 15.47 mg into twenty-one separate ceilings, from 15.47 mg in first position down to 0.737 mg in twenty-first. The best-case page works through all of them.

See all twenty-one ceilings →

The limits

What descending order does not give you

  • A floor. Nothing stops an ingredient from being present at a microgram, as long as the order holds.
  • A tie-break. Several ingredients may weigh exactly the same, and the printed order tells you nothing about which.
  • A guarantee that the order was verified. It is an assertion by the manufacturer.
  • Anything about the form, the standardisation or the quality of what was used.

This matters because a ceiling is a one-sided bound. Saying an ingredient is at most 0.737 mg is not saying it is 0.737 mg. The true figure could be a hundredth of that. Every number on the best-case page is the most favourable reading available, and the argument is that even the most favourable reading does not work.

A method

How to read any blend in ninety seconds

  1. Find the total

    It sits to the right of the blend name. If there is no total, the label is out of compliance and that is worth knowing on its own.

  2. Count the ingredients

    Write the number down. Twenty-one here.

  3. Divide

    Total divided by the count gives the average. If the blend were split evenly, every ingredient would get that much. Here it is 0.737 mg.

  4. Look up position one

    The first-named ingredient can hold the whole total. If the whole total is still below that ingredient's researched dose, nothing in the blend reaches a researched dose.

  5. Check the bottom third

    Divide the total by the count to get the last position's ceiling. Compare it with what those ingredients are studied at. On this label the bottom ten are amino acids studied in grams.

  6. Decide

    You now know more about the formula than the label intended to tell you, and you did it with division.

Step four is where most blends end. If the entire declared total is smaller than the smallest researched dose of the first-named ingredient, the formula cannot deliver a studied dose of anything, and no amount of ingredient count changes that.

The fair reading

Blends are not automatically bad

It would be easy to write this page as though every proprietary blend were dishonest. That is not true and it is not useful.

  • A blend of three ingredients totalling 1,200 mg leaves each one a 400 mg average and a 1,200 mg ceiling. Several of those ceilings sit inside real research.
  • A blend that names a standardised extract and gives its total can be assessed even without the split.
  • Some categories — flavour systems, enzyme complexes — genuinely do carry formulation value worth protecting.

The question is never whether a label uses a blend. It is whether the blend total is large enough for the ceilings it produces to mean anything. Fifteen milligrams across twenty-one names answers that question without needing an opinion.

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Sources

References

Every source below was opened and read. Nothing here cites a study we did not read, and no identifier on this site was written from memory.

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The best caseThe ceilings, with the extract ratios granted on top.Read it →The panelEvery line as printed.Read it →The guidesLonger reads on reading labels.Read it →
Cognizil — 30 ml, 30 days21 ingredients in 15.47 mg · from $49 a bottleSee the packs