Research note
Reading the 154 mg blend: the descending-order rule, worked numbers and the questions to send
A proprietary blend hides the split but not the order. From that order alone you can bound each extract, total the bottle, and know exactly which numbers to request from the seller.
The rule that shapes every proprietary blend
Federal labeling law lets a supplement group ingredients under a named "proprietary blend" and print only the total weight of the group. The trade-off is a single requirement: the ingredients inside must be listed in descending order of predominance by weight [1]. The label does not have to tell you how much of each one is present, only which is heaviest.
Breathizen's panel uses this option for everything that is not water, glycerin, flavor or a preservative. One line reads "Proprietary Blend 154 mg", followed by mullein leaf extract 10:1, ginger root extract and organic lemon extract, in that order.
Worked arithmetic for a three-ingredient blend
Order alone sets more limits than most buyers realize. With three ingredients and a total of 154 mg:
| Position | Rule | Bound for Breathizen |
|---|---|---|
| 1st: mullein | Must be at least one third of the total | 51.3 mg or more, under 154 mg |
| 2nd: ginger | Cannot exceed the first, so at most half the total | 77 mg or less |
| 3rd: lemon | Cannot exceed the second, so at most one third | 51.3 mg or less |
Every split below obeys the label, which is exactly the problem: the panel cannot tell them apart. These are illustrations, not the recipe.
| Possible split | Mullein | Ginger | Lemon | What it would mean |
|---|---|---|---|---|
| Even thirds | 51.3 mg | 51.3 mg | 51.3 mg | The most ginger and lemon the label permits together |
| Mullein-heavy | 120 mg | 24 mg | 10 mg | Mostly leaf extract, a trace of the others |
| Ginger near its cap | 76 mg | 70 mg | 8 mg | Ginger close to 77 mg, lemon almost a garnish |
| Lemon as flavor | 100 mg | 50 mg | 4 mg | Lemon present mainly for taste |
What you can safely work out from the panel
- The ranking: there is at least as much mullein as ginger, and at least as much ginger as lemon.
- The ceilings: ginger 77 mg, lemon 51.3 mg, mullein below 154 mg, per 4-pump serving.
- The bottle totals: 100 servings x 154 mg = 15.4 g of blend per 60 mL bottle, so the blend makes up about a quarter of the liquid's weight at most, the rest being water, glycerin and the minor additives.
- The concentration per pump: about 38.5 mg of blend in each 0.15 mL press, if the four presses are equal.
- The cost of the blend: on the six-bottle pack, $294 buys 92.4 g of blend, about $3.18 per gram.
What the panel keeps from you
- The exact milligrams of each extract, which is the number you would need to compare against any study.
- The solvent, standardization marker or active compound content of the mullein and ginger extracts.
- Which part of the lemon was used, and whether "organic lemon extract" is a flavor-level addition or a functional one.
- Lot test results: identity, heavy metals or microbial counts. Federal manufacturing rules require the maker to verify these internally [2], but nothing obliges them to publish.
- Why the sales page lists bromelain and cordyceps that the panel does not mention.
Claims on a supplement label must stay within structure and function language, carry the FDA disclaimer, and avoid disease claims [3]. A blend can be fully legal and still be uninformative; legality and transparency are separate tests.
How to ask the seller for the missing numbers
You are entitled to ask, and a polite, specific email gets better answers than a general complaint. Send something like this to [email protected]:
Hello, I bought Breathizen (order number ____, lot number ____ from the bottle). Could you share the milligrams of mullein leaf extract, ginger root extract and organic lemon extract in the 154 mg blend, the extraction solvent, and a certificate of analysis for my lot? Thank you.
A clear answer is a good sign; a refusal tells you something too. Either way, the FDA's general guidance on supplements suggests asking manufacturers exactly these questions [4], and NCCIH's advice on using supplements wisely adds checking with your own clinician [5]. Our manufacturing and unboxing section explains what a real certificate of analysis should contain, and the mullein and ginger notes apply these bounds to each extract.
Questions buyers ask here
Why doesn't the Breathizen label list each ingredient amount?
Because it uses a proprietary blend, which federal rules allow. Only the 154 mg total and the descending order must be printed; individual amounts can stay confidential.
Is a proprietary blend legal?
Yes. It is permitted under 21 CFR 101.36 as long as the total weight and descending order are shown. Legal does not mean informative, which is why we print the bounds.
Can I calculate the exact milligrams of mullein, ginger and lemon?
No, only ranges: mullein at least 51.3 mg, ginger at most 77 mg, lemon at most 51.3 mg per serving. The exact split requires the seller's formula or a lab test.
Sources linked from this page
Each link opens the original record. The studies tested single ingredients at their own doses and routes; none of them tested the Breathizen spray or its 154 mg blend.
- 1Electronic Code of Federal Regulations. 21 CFR 101.36: Nutrition labeling of dietary supplements (proprietary blend rule in paragraph (c)). www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-C/section-101.36
- 2Electronic Code of Federal Regulations. 21 CFR Part 111: Current Good Manufacturing Practice for dietary supplements. www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-111
- 3Electronic Code of Federal Regulations. 21 CFR 101.93: Certain types of statements for dietary supplements. www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-F/section-101.93
- 4U.S. Food and Drug Administration. Questions and Answers on Dietary Supplements. www.fda.gov/food/information-consumers-using-dietary-supplements/questions-and-answers-dietary-supplements
- 5National Center for Complementary and Integrative Health. Using Dietary Supplements Wisely. www.nccih.nih.gov/health/using-dietary-supplements-wisely
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