What a proprietary blend hides, and what it cannot
This is the most important thing to understand about the CogniMary label, and about most labels in this category. It takes about five minutes.
A proprietary blend lets a US supplement label publish one total weight for a group of ingredients instead of an amount for each. It is legal under 21 CFR 101.36(c). The label must still name every ingredient in the blend and list them in descending order of weight.
That ordering requirement is the buyer's lever: it puts a mathematical ceiling on every ingredient in the list, without anyone disclosing anything further.
The regulation, in its own words
21 CFR 101.36 governs the nutrition labelling of dietary supplements. Paragraph (c) is the one that covers blends. Two requirements matter.
What the regulation says
“A proprietary blend of dietary ingredients shall be included in the list of dietary ingredients … and identified by the term ‘Proprietary Blend’ or other appropriately descriptive term or fanciful name.”
“The quantitative amount by weight specified for the proprietary blend shall be the total weight of all other dietary ingredients contained in the proprietary blend and shall be placed on the same line to the right of the term ‘Proprietary Blend’.”
The ingredients inside must then be listed by name, indented beneath the blend line, in descending order of predominance by weight — without individual amounts.
On the CogniMary panel, the “fanciful name” is WMG-NVT Exclusive Blend, the total is 635 mg, and the eleven ingredients are indented below it in order.
Why blends exist
It is worth putting the honest case before the criticism, because the case is not nothing.
Formulas are copyable
A full disclosure is a recipe. A competitor can read it on a shelf, match it, and undercut the company that paid to develop it. Nothing stops them.
The stated reason
Ratios can be the innovation
In a formula where the proportions are the work rather than the ingredient list, publishing the split does hand something away.
Sometimes true
Supply changes
Extract strengths shift between harvests and suppliers. A blend total is easier to hold constant than eleven individual figures.
A practical argument
All three are real. None of them is a reason a buyer should be content with the result, any more than a restaurant's reasons for not publishing a recipe help someone with an allergy.
What a blend costs the buyer
- You cannot check a dose. Every trial that supports an ingredient used a specific amount. Without the split you cannot tell whether the product reproduces it.
- You cannot compare two products. Two labels can name the same eleven ingredients and contain wildly different quantities of each.
- You cannot price it properly. Expensive ingredients can sit at the bottom of the list in trace amounts while a cheap one fills most of the total.
- You cannot manage an interaction. If you take an anticoagulant and the blend contains ginkgo, “some ginkgo” is not enough information for a clinician.
- It hides the cheap fill. The heaviest ingredient is first. If that is the cheapest one on the list, the blend total flatters the formula.
The last two are the ones we would raise with a clinician and with a seller respectively. The interaction point in particular is not a philosophical objection; it is a practical one that comes up in a pharmacy.
Reading a blend as a buyer
Four steps that work on any label in any category, not just this one.
Read the position, not just the name
First on the list is the heaviest. Last is the lightest. On a long list, the ingredients that sold you the product are often near the bottom.
Divide the total by the position
That gives the ceiling for each one. It takes ten seconds with a phone and it is the single most useful thing you can do with a blend.
Compare that ceiling with a researched dose
One good search per ingredient. If the ceiling is under the dose, the product cannot reproduce the study, whatever the marketing says.
Count the names
A long ingredient list inside a small total is the clearest signal in this industry. Eleven names in 635 mg is a crowded blend by any standard.
Applied to this label, step two gives you the ceiling chart, and step four gives you the headline: eleven names, 635 milligrams, an average of 58 mg each if they were split evenly, which they are not.
What an open label looks like instead
A growing number of supplement companies publish every amount. The practice is usually called open-label or full-disclosure dosing, and it is not a regulatory requirement — it is a choice.
| A blend label | An open label |
|---|---|
| “Proprietary Blend 635 mg” with eleven names below it | Eleven lines, each with a number |
| Ceiling can be derived; content cannot | Content is stated |
| Comparison between products is impossible | Comparison is arithmetic |
| Protects the formula from copying | Does not |
| Legal | Also legal |
There is no regulator to appeal to here. Both labels comply. The difference is what each one is willing to tell you, and that is information about the seller as much as about the product.
The questions worth asking a seller
- What is the milligram amount of each ingredient in the blend?
- What is the extract ratio or standardisation for each botanical?
- Which species is the bilberry, and can you provide an identity test?
- How much EGCG is in a serving, given the green tea extract is standardised to not less than 50%?
- Can you send the certificate of analysis for the lot I received?
A seller who answers those five has told you more than the label can. A seller who declines has also told you something. Either way the questions are worth asking, and this site's own desk is +1 (302) 200-3480 if you want to start with us.
Our own answer, for the record
We do not have the split. This is the retailer's site, not the manufacturer's, and the information supplied to us for this build is the same information published on the label. Where we have asked a question we could not answer, it is on the about page under what is missing.
Order CogniMary from the official website
Sixty capsules, thirty days, and a panel you can read before you buy. Start with one bottle so you can see the price and the guarantee term before you commit to six.
No price was published to this website. The figure is on the checkout page.
What other countries do
The proprietary blend is a feature of US labelling. It is worth knowing that the approach is not universal, because it makes clear that the current rule is a policy choice rather than a physical necessity.
In several other jurisdictions, supplement and food-supplement labelling requires the quantity of each active ingredient to be declared, which makes a blend of the kind on this label impossible to sell in the same form. Products are reformulated or relabelled for those markets.
We are stating that generally rather than naming a specific regulation, because we did not open the text of a foreign regulation for this page and we are not going to cite one we did not read.
The relevant point for a US buyer is simpler: the same manufacturer, with the same formula, is capable of printing the amounts. The question a blend raises is not whether disclosure is possible.
How the blend interacts with everything else on a label
- It makes the ingredient count the selling point. If amounts cannot be compared, the only comparable number left is how many names are on the list, which rewards crowding.
- It makes standardisation figures less useful. “Not less than 50% EGCG” is precise about a proportion of an unknown quantity.
- It makes interactions harder to manage. A clinician asked about ginkgo and an anticoagulant needs an amount, and there is not one.
- It makes the cost per active ingredient unknowable. You cannot tell whether you are paying for the expensive ingredient or the cheap one.
- It makes trials impossible. Nobody outside the company could run a study of the formula and describe what they gave people.
That last one is the quiet consequence. A blend does not only hide the formula from buyers; it removes the formula from the scientific record entirely.
In short
A proprietary blend publishes one total and hides the split, which is legal. The same regulation requires the ingredients to be listed heaviest first, which hands the buyer a ceiling for every position. Divide the total by the position, compare with the researched dose, and you have recovered the only part of the formula the label was willing to give you.
One sentence
A blend hides how much of each ingredient you are buying, and the ordering rule that comes with it hands you a ceiling for every one of them.