Updated November 2025.
DIETITIANS are allowed to recommend vitamins and minerals as part of a complete nutritional assessment and nutrition care plan. It is important to understand the limitations imposed by laws before making recommendations to your clients.
Prescribing vs. Recommending
Knowing the difference between recommending versus prescribing can help us better understand the limits of the law. The Regulated Health Professions Act is a law with regulations about higher risk activities that could be harmful when performed by an unqualified person. These are called “controlled acts.”
In Ontario, the act of prescribing certain drugs is a controlled act. Authorized healthcare providers, such as physicians can prescribe drugs. Dietitians are not allowed to prescribe a drug without receiving a delegation from a physician.
On the other hand, recommending a vitamin or mineral supplement, including its dose and frequency, is not usually a controlled act. Recommendations might include educating clients about the benefits of certain vitamins and minerals, as well as recommending them as part of a complete nutrition assessment and treatment plan.
When are vitamins and minerals drugs?
Sometimes, certain vitamins and minerals at higher doses or dosage forms may be a drug. For example, components of total parenteral nutrition (TPN) are scheduled drugs, as well as high doses of vitamin D. The National Association of Pharmacy Regulatory Authorities categorizes drugs by schedules. These schedules help identify drugs that:
- require a prescription for sale,
- need intervention from a pharmacist,
- can be self-selected, or
- need professional supervision.
Dietitians can check whether a recommended supplement dose or dosage form is a drug using the National Association of Pharmacy Regulatory Authorities database. This database lists all scheduled drugs.
- Schedule I drugs require a prescription for sale and are provided to the public by the pharmacist following the diagnosis and professional intervention of a health care provider.
- Schedule II drugs require professional intervention from the pharmacist at the point of sale and possibly referral to a health care provider. While a prescription is not required, these drugs may still be prescribed. The drugs are available only from the pharmacist usually behind the counter. An example of a schedule II drug is insulin.
- Schedule III drugs are available without a prescription and are sold from the public area of the pharmacy. A prescription is not required but these drugs are still often prescribed. An example of a schedule III drug is the laxative, Lactulose.
- Unscheduled drugs can be sold without professional supervision and may be sold from any retail outlet. Examples of unscheduled drugs are a lower dose of ibuprofen or the antacid, Tums.
For example, vitamin D is a schedule I drug in an oral dosage form above 2,500 international units (IU). In this case, a dietitian cannot recommend 2,500 IU (or more) per dosage form, as it would be prescribing a drug. The dietitian needs an authorized prescriber to delegate the authority to prescribe this since it is classified as a scheduled drug.
Can dietitians prescribe?
In Ontario, dietitians are not authorized to prescribe a drug. Dietitians can be delegated to perform the controlled act of prescribing a drug from a healthcare provider who has prescribing authority, like a physician. This can be delegated through a direct order or a medical directive.
Dietitians who have the knowledge, skill and judgment (competence) can accept these delegations. The College has outlined minimum practice expectations for dietitians who perform controlled acts in the Dietitians Practising Through Delegation of Controlled Acts standard.
What is not a drug
Products with a Natural Health Products Number (NPN) are no longer part of the national drug schedules. This means that natural health products, such as vitamins and minerals and homeopathic remedies are not classified as scheduled drugs. The following are not drugs:
- Food and drinks.
- Vitamin and mineral supplements (that are not listed in the National Association of Pharmacy Regulatory Authorities database).
- Herbal remedies.
- Homeopathic medicines.
- Traditional medicines (including traditional Chinese medicines).
- Natural health products such as probiotics, essential fatty acids, and amino acids (not in parenteral form). 1
- Some enzyme products that have NPNs like Lactaid, Beano.
- Oral nutritional supplements like Ensure.
- Other products, such as castor oil.
Depending on your practice setting, there are some limitations on how dietitians may implement vitamin and mineral recommendations.
Community Setting
In a community setting, such as public health, home care, or private practice, dietitians do not need an order to recommend unscheduled vitamins and minerals, and oral nutritional supplements.
Hospital Setting
However, in a public hospital, dietitians need an order to recommend a treatment, including vitamins and minerals. This is because the Public Hospitals Act only allows a physician, nurse practitioner, dentist, or midwife to order treatments or diagnostic procedures.
Even though recommending unscheduled vitamins and minerals does not fall within the controlled act of prescribing, dietitians require an order from one of the healthcare providers listed. This allows a patient to receive vitamins or minerals as part of their treatment. If dietitians wish to recommend vitamins and minerals that are scheduled drugs in an inpatient setting, a delegation would be required to allow this treatment order. The delegation to prescribe can occur via direct order or a medical directive.
In some outpatient hospital settings, dietitians may need an order to recommend vitamins and minerals. Most outpatient programs are structured less formally, and orders are not required for every intervention or treatment recommendation. If an outpatient program does fall under the Public Hospitals Act, then orders are required for every intervention, including vitamin and mineral recommendations. Dietitians can check with their organization to check how their outpatient department is structured.
Long-Term Care Setting
In long-term care homes, there are no legal restrictions on dietitians recommending vitamins and minerals to residents. The Fixing Long-Term Care Act does not restrict orders for treatment or diagnostic procedures. This means dietitians can usually write diet orders for vitamins and minerals in this setting. In some cases, certain long-term care homes may have policies that dietitians need a doctor’s co-signature to order diets, as well as vitamin and mineral recommendations.
Dietitians should consult their long-term care homes’ organizational policies in case there are rules about this practice.
Providing Samples and Selling Vitamins and Minerals
If a dietitian wants to provide a sample or sell a vitamin or mineral product to a client, there are some things to consider.
- Check if the product is a scheduled drug using the National Association of Pharmacy Regulatory Authorities database search option.
- If it is a scheduled drug, dietitians must have the delegated authority to dispense or provide samples.
- If it is an unscheduled drug, or a natural health product, it may be provided or sold without a delegation (order or directive).
- Check for any organizational policies for giving samples or sales of these products.
- Be sure products provided or sold are in the client’s best interest, and are evidence informed.
- Document in the client’s health record.
- Ensure you are not practising in a conflict of interest, if recommending and selling vitamin and mineral products.
Safety and Accountability of Samples
Clients trust that dietitians recommend or provide samples that are based on their needs, are safe and evidence informed. Dietitians have a professional responsibility to make sure samples:
- Are stored securely.
- Are current and are not past their ‘best before’ or expiry dates.
- Have clear records of their origin and distribution.
Searching the Database
When searching the National Association of Pharmacy Regulatory Authorities database, you must use the drug name and not the brand name of the drug. The database does not list private label products, such as Life brand. Alternatively, you can contact a pharmacist to confirm whether something is a scheduled drug.
Key Takeaways
- Dietitians can recommend unscheduled vitamins and minerals within their scope of practice based on their nutritional assessment.
- Check the drug database before recommending vitamins and minerals, especially if you are not sure if it is a scheduled or unscheduled drug.
- Dietitians can only recommend scheduled drugs, such as high-dose vitamin D with a delegation via direct order or medical directive.
- Products that are not scheduled drugs, like natural health products, can be recommended by dietitians.
- Practice setting can affect authority, especially for dietitians working in hospitals and long-term care homes.
- Check if a product is a scheduled or unscheduled drug before providing samples.
References
College of Dietitians of Ontario (2020). Standard for Dietitians Practising Through Delegation of Controlled Acts.
Government of Ontario. Fixing Long-Term Care Act, 2021.
Government of Ontario. Public Hospitals Act. (1990).
Government of Ontario. Regulated Health Professions Act, 1991.
National Association of Pharmacy Regulatory Authorities (2025). National Drug Schedule.
Footnotes
1 Health Canada (2022). Natural Health Products.
