E.U. Nutritional table and Nutritional claims – What do nutrients mean?
The importance of a compliant label
The nutritional table across E.U. became mandatory on (almost) all foods on December 13th, 2016. Until that day, a nutritional table used to appear on a food label only if a nutritional claim (i.e., “source of protein,” “low fat,” etc.) was on the label itself.
A standardized nutritional table is the milestone of correct communication to consumers, providing a nearly uniform way of presenting the nutritional values of a given food. From this point of view, it is mandatory to list all nutrients in the same order to aid consumers in finding relevant information in the easiest way possible.
Again, when the food industry uses a nutritional claim, it must follow precise indications. The food manufacturer can use a typical claim about any nutrient only if it appears in a certain amount (or does not overcome a certain amount in some cases).
List of mandatory information
On each label, the following values are mandatory:
- Energy (both in kJ and kcal)
- Fat (g)
- Saturates (g)
- Carbohydrate (g)
- Sugars (g)
- Protein (g)
- Salt (g)
List of voluntary information
On each label, the following voluntary information can appear to complement the mandatory ones:
- mono-unsaturates (g)
- polyunsaturates (g)
- polyols (g)
- starch (g)
- fiber (g)
- any allowed vitamin or mineral present in significant amount* (mg or µg)
Presentation and positioning
There are no restrictions on positioning the Nutritional table, setting aside the legibility, which food industries have to consider. The food manufacturer has not to hide, obscure, detract from, or interrupt the nutritional information by any other written, pictorial matter or intervening material.
Nutritional values shall be in a tabular format. Suppose there needs to be more space on the package. In that case, the food industry can present them alternately (typically linear).
The food industry has to list all values “per 100g or 100ml”. In some instances, this can be awkward, as some foods are unlikely to be consumed in such a quantity, and either can obtain them:
- the food analysis of the manufacturer;
- a calculation from the actual or known average values of the ingredients used; or
- an estimation from generally established and accepted data.
For vitamins and minerals only, in addition to the presentation per 100g, it shall be mandatory the expression as a percentage of the reference intakes set in the following table:
*As a rule, the food industry should take into consideration the following values when deciding which amount is significant:
- 15 % of the nutrient reference values specified in the table above are supplied by 100 g or 100 ml (for products other than beverages),
- 7,5 % of the nutrient reference values specified in the table above are supplied by 100 ml in the case of beverages or,
- 15 % of the nutrient reference values of the table above per portion if the package contains only a single piece,
In addition to the form of presentation per 100g, nutrients can be listed as “per portion” established by the manufacturer, provided the exact portion is close to the Nutritional table. The number of pieces is listed as well.
Note that the food industry can use the above percentage only for those nutrients for which there is a reference intake. Therefore, for example, no % shall ever be listed for Fiber (the most common mistake regarding this specific topic).
Nutritional claims are regulated by E.C. Reg. 1924/06, which addresses when a nutritional claim can occur and under which conditions. Regulation statements apply to food labels and to every media used to present the food to the consumer. For example, a traditional one – a flyer, a magazine, a T.V. advertisement, or a more “recent” one – distance selling on the Internet, QR codes, etc.).
According to the Regulation, five are the main features of a nutritional claim; it must not:
- Be false, ambiguous, or misleading;
- Give rise to doubt about the safety and/or the nutritional adequacy of other foods;
- Encourage or condone excess consumption of food;
- State, suggest, or imply that a balanced and varied diet cannot provide appropriate quantities of nutrients in general.
- (e) refer to changes in bodily functions that could give rise to or exploit fear in the consumer, either textually or through pictorial, graphic, or symbolic representations.
Each nutritional claim must be accurate and supported by scientific evidence if needed. Most importantly, it aims to grant the target nutrient in the final product in such a quantity to provide the claimed beneficial effect.
Last but not least, the usually consumed amount of food provides a significant quantity of the nutrient or other substance to which the claim relates.
For a complete list of all the allowed nutrition claims, along with the fulfillment conditions, see Annex of E.C. Reg. 1924/06
Following is a short list of all claims currently authorized, which can therefore exist on a food label:
- Low energy
- Low fat
- Low saturated fat
- Saturated fat-free
- Low sugars
- With no added sugars
- Low sodium/salt
- Very low sodium/salt
- Sodium-free salt-free
- No added sodium/salt
- Source of fiber
- High fiber
- Source of Protein
- High protein
- Source of [name of vitamin(s)] and/or [name of mineral(s)]
- High [name of vitamin(s)] and/or [name of mineral(s)]
- Contains [name of the nutrient or other substance]
- Increased [name of the nutrient]
- Reduced [name of the nutrient]
- Source of omega-3 fatty acids
- High omega-3 fatty acids
- High monounsaturated fat
- High polyunsaturated fat
- High unsaturated fat
Let’s focus on a couple of claims to understand better their general “structure.”
A claim that a food is sugar-free, and any claim likely to have the same meaning for the consumer, may only be made where the product contains no more than 0,5 g of sugars per 100 g or 100 ml.
The above is a pretty linear, straightforward claim with no particular conditions. However, what is of interest here is the text in bold. As a result, the manufacturer has a good range of options, letting them differentiate from the used claim. The industry can declare that food is sugar-free differently; therefore, a consumer should not expect to find the exact wording mentioned above.
And this is where the Regulation might prove fallacious. “Same meaning for the consumer” is a statement that is not black or white but lies in the “shades of grey.” Nobody can define what the average consumer is capable of understanding; therefore, the advice should be to use the prescribed wording to avoid any possible issue.
Since each definition contains the sentence mentioned above, this problem is common to (pretty much) all the claims in the list.
Where a food naturally meets the condition(s) laid down in this Annex for the use of a nutritional claim, the term ‘naturally/natural’ may be used as a prefix to the claim.
This second claim, rather than clarifying things, poses an interesting question. Both manufacturer and consumer can determine something that needs to be clarified. Nobody can tell when a given food meets any condition “naturally.” And this is why the term “natural” will be the object of some future discussion in the E.U. regulatory framework. Again, the text in bold is our focus.
At present, using this cl is both risky and potentially misleading.
Nutrition claims – Comparative claims
Comparative claims are allowed but under some conditions. Of course, the comparison must refer to one or more nutrients. Therefore, a possible claim could be “20% more protein compared to…” or similar.
The claim must refer to foods belonging to the same category. It is impossible to compare a cookie and a soup, but a comparison between two cookies can occur.
One key feature of the claim is that the industry has to declare the difference in the quantity of a nutrient, and the comparison shall relate to the same amount of food.
It would be possible to compare two products of the same brand, like “new recipe, now with 20% fat less”, as it would be possible to compare other brands.
The only restriction on type size is the one that is common to all mandatory information on the label. The type size must be at least 1,2 mm, using the lower-case letter “x” as a reference. The x-height of the font size shall be equal to or bigger than 0,9 mm. In the case of containers or packaging, the largest surface has an area of less than 80 cm 2.
- REGULATION (E.C.) No 1924/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of December 20th, 2006, on nutrition and health claims made on foods
- REGULATION (E.U.) No 1169/2011 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of October 25th, 2011, on the provision of food information to consumers