As scientific evidence linking diet and health expands and deepens, the need to provide more nutritional information to consumers has been recognized. One of the main drivers for nutrition labelling is the increased prevalence of diet-related noncommunicable diseases. Labelling is useful for promoting consumption of foods containing vitamins, minerals and protein as well. The main types of nutrition labels are described below.
A nutrient declaration label is a standardized statement or listing of the nutrient contents of a food. Codex recommends that this should be mandatory on all packaged foods except where national circumstances would not support such declarations. The declaration must be on all packaged foods that carry a nutrition claim. Nutrient declarations can be presented per serving or per 100g/100ml; and if expressed per serving or portion, the serving size or number of portions contained in the package should be stated. Serving size must be based on the food as it is sold. For foods requiring preparation and foods commonly mixed with other ingredients or another food before being eaten (for example, pudding mix, soups or breakfast cereal with milk), information on the food as prepared can also be included. Food labelling laws that mandate that the nutrient declaration must be made by serving size often have standardized predefined serving sizes or a range of serving sizes to allow flexibility set by national governments based on national dietary intake data.
Where nutrient declaration is applied, the following nutrients must be included: energy value (calories), amounts of protein, available carbohydrate (that is, dietary carbohydrate excluding dietary fibre), total fat, saturated fat, sodium (or salt equivalent) and total sugars must be declared. Additionally, the amount of any other nutrient that is considered to be relevant for maintaining good nutritional status in national legislation or national dietary guidelines must be declared.
Calculations and food composition:
It is the manufacturer’s responsibility to ensure that the declared values accurately reflect the contents of the product. Although manufacturers can determine the energy value directly through analysis, the energy value is usually calculated by analyzing the protein, fat and carbohydrate levels for these nutrients and then multiplying them by the Atwater conversion factors, unless a different factor is given in a Codex standard or in the Codex method of analysis for that food.
Several public websites are available for calculating the nutritional composition of foods. It should be noted that food composition data used in these applications represent an average of the nutrient content of a particular sample of foods and ingredients, determined at a particular time, which can vary substantially between different batches and brands. Such differences can be the result of a number of factors, including changes in season, processing practices, and ingredient sources. Before relying on calculated nutritional values generated by food databases, a manufacturer
should carefully evaluate the accuracy, completeness and relevance of the results for their purposes. Manufacturers should obtain expert advice in developing their nutrition labels. When developing the labelling policies, authorities should provide guidance on food composition.
When making the nutrient declaration, information on protein and additional nutrients may be expressed as percentages of the Nutrient Reference Values (NRV) where an NRV has been established. NRVs are a set of numerical values that are based on scientific data associated with nutrient requirements or associated with the reduction in the risk of diet-related noncommunicable diseases. NRVs are derived for the purposes of nutrient declaration and relevant claims on food labels.
The nutrients within the nutrient declaration can be presented as the % NRV. The % NRV provides a quick overview of the nutrient levels in a food. A consumer can use the % NRV to compare two different food products to help choose foods that are higher in the nutrients they desire and lower in the nutrients they want to reduce or avoid. For optional nutrients, values <5% NRV should not be declared.
Codex provides NRV values for many vitamins and minerals, as well as protein. One type of NRV is the Nutrient Reference Values – Requirements (NRVs-R) which refer to NRVs that are based on levels of nutrients associated with nutrient requirements.
In addition, Codex has defined Nutrient Reference Values – Noncommunicable Disease (NRVs-NCD) which refer to NRVs that are based on levels of nutrients associated with the reduction in the risk of diet-related noncommunicable diseases not including nutrient deficiency diseases or disorders. Three NRVs-NCD have been established to date and others are under discussion (for example EPA and DHA Long chain Omega 3 fatty acids):
Nutrient declarations are usually presented in a standard format on the back of the package or side of the package.
Some countries have established their own NRVs based on recommendations that have been developed using data from their own population such as the Daily Value (DV) adopted in the USA and Canada, or Daily Intake (DI) in Australia. It is recommended that expert advice be sought when setting country-specific NRVs for national labels.
In addition to the nutrient declaration, nutrient claims can be made on the food label on a voluntary basis. The use of nutrient claims on the food label is under the discretion of the food company as long as the food meets the criteria, as outlined in national food labelling legislation in the country where it is being sold. Therefore, it is important to have criteria defined within food labelling legislation to prevent misleading or false claims.
Nutrition Claims are any representation which states, suggests or implies that a food has particular nutritional properties. Usually, the only nutrition claims permitted shall be those relating to energy, protein, carbohydrate, and fat and components thereof, fibre, sodium and vitamins and minerals for which Nutrient Reference Values (NRVs) established in the Codex Guidelines for Nutrition Labelling.
Nutrition claims can be categorized as either nutrient content or nutrient comparative claims.
Experience and research indicate that consumers often need more guidance for selecting foods for a healthy diet than is given by nutrient declarations, ingredient lists and claims. Front of Package (FOP) systems and symbols summarize key nutritional aspects and characteristics of food products and often integrate characteristics of traditional nutrition labels, as well as nutrition and health claims. The FOP label is easily seen in the market and attracts consumers’ attention. These labels are typically found on a product’s principal display panel, but may be elsewhere on the food label.
Research has also demonstrated that simplified labels promote more accurate evaluations of foods by consumers. In the United States of America, the Institute of Medicine (IOM, 2010) classified FOP systems and symbols in use internationally at the time, these included:
Nutrient-specific systems: These are either systems that display the amount per serving of calories or select nutrients from the nutrient declaration on the front of pack, or symbols based on nutrition or health claim criteria.
Summary indicator systems: These are symbols, icons, or scores that provide summary information about the nutrient content of a food but give no specific nutrient content information to consumers. Summary indicator systems attempt to assess the overall healthiness of a food using either thresholds or algorithms. Threshold-based systems typically establish maximum levels for nutrients to limit, and minimum levels for nutrients or food components to encourage, to judge whether a product qualifies for a summary indicator symbol. Algorithm-based systems award points for the presence of nutrients or food components to encourage and subtract them for the presence of nutrients to limit to arrive at a final score that is used as the summary indicator symbol.
Food group information systems: These include symbols that indicate that a food group (such a vegetables and fruit) or a food ingredient important to the diet (such as whole grains) is present in a food product.
At the present time, most countries do not have specific regulations for FOP nutrition rating systems and Codex has not provided guidance on this type of label. However, at the 43rd Session of the Codex Committee on Food Labelling held in May 2016, the Committee agreed to establish an electronic Working Group to consider the need for development of global principles to underpin front-of-pack nutrition labelling. In Norway, Sweden, Finland and Iceland, a regional “keyhole” FOP has been used for a number of years. Australia and New Zealand have released a “healthy star” FOP recently. The United Kingdom has developed a “traffic light” FOP over several years. In Europe and the USA, governments have begun to pursue strategies to standardize voluntary FOP systems with government-developed nutrient profiling criteria.
Codex does not outline specific health claims for use on labels or their criteria. Permitted health claims and their criteria are defined and approved by the national authority in each country to avoid false, misleading and unsubstantiated claims. Products should only be bear a health claim if the claim is approved in the country where the product is being sold. A health claim should be approved if the claim is substantiated with current relevant scientific evidence and should be re-evaluated when new knowledge becomes available. Additional information is provided by Codex to help competent national authorities in their evaluation of the evidence for the scientific substantiation of health claims. It is recommended that expert advice be sought when establishing a framework for health claim substantiation. Overall, substantiation of a health claim involves a systematic review of the scientific evidence. This often includes the following tasks:
The evidence used to substantiate a health claim should be based on well-designed human interventions demonstrating a consistent association between the food or food constituent and the health effect when consuming a reasonable amount of the food or food constituents. Other types of studies are generally not sufficient to substantiate a health claim on their own.
The systematic review can be carried out by national authorities or the systematic review can be conducted by industry applicants and submitted to national authorities for review and approval. Both approaches benefit from consulting expert advice on the specific food and health relationship. Some countries have published scientific and technical guidance on how to prepare a submission for health claim approval.
When approving a health claim for use in the marketplace, it is important to consider if the amount of the food or food constituent exposes the consumer to health risks or known interactions that may pose health risks and/or exceeds relevant upper levels of intake for the food or other constituents. Exposure assessments should be conducted and be based on an evaluation of the distribution of usual total daily intakes for the general population and, where relevant, for vulnerable population sub-groups.
Clear qualifying and/or disqualifying conditions for eligibility for foods to use the specific claim should be established. Claims on foods that contain nutrients or constituents in amounts that increase the risk of disease or an adverse health-related condition should be prohibited.
The Codex General Guidelines on Claims details a number of general principles regarding the use of claims on foods, including prohibited claims and potentially misleading claims. The following claims should be prohibited:
The Codex provides a few examples of claims which may be misleading and should be avoided:
Examples of misleading labels are shown below:
Ambiguous health statements such as “helps maintain a healthy heart” or “supports the immune system” are not upheld to the same standards as reduction of disease risk claims although consumers may not always perceive the difference.
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