Is a functional mushroom beverage regulated as a food or a supplement?

It depends on labeling and claims. RTD beverages with general wellness positioning typically require a Nutrition Facts panel and are regulated as conventional food under FDA's FSMA rules. Products with structure/function claims (e.g., 'supports cognitive function') sold as dietary supplements need a Supplement Facts panel and FDA disclaimer. Misclassifying your product is a common and costly mistake — always confirm with a regulatory expert or a compliant co-packer before finalizing your label.