Issues related to content claims, comparative claims and nutrition claims
1. Q: Can content claims and comparative claims appear in other large paragraphs on the packaging label? Can it appear in promotional media such as TV ads or image ads?
A: Nutrition claims and nutritional facts function claims can be placed anywhere on the label, but their labels should comply with the provisions of this standard; they can appear in promotional media such as TV advertisements or image advertisements, but they should comply with national laws and regulations on food advertising.
2. Q: For a substance that is both a food additive and a nutritional fortifier, when it is only used as a food additive, can it be labeled in the nutrition facts and make a nutrition claim?
A: For substances that are both food additives and nutritional fortifiers, if they are used as food additives, manufactures can choose whether to label them in the nutrition facts. When their content meets the requirements of this standard, corresponding nutritional claims can also be made.
3. Q: Natural mineral water contains K, Ca, Na, Mg and other minerals, but most of the content cannot meet the requirements of the content of minerals claimed in GB28050-2011. Does the product label claim to contain minerals such as K, Ca, Na, Mg?
A: According to the provisions of GB28050-2011 "National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods", nutrition claims refer to the description and declaration of the nutritional characteristics of foods, including content claims and comparative claims. The content claim refers to the claim that describes the level of energy or nutrient content in the food. The terms of the claim include "contains", "high", "low", "no", "rich", etc. Therefore, if a company declares "contains a certain nutritional ingredient" or similar terms on the product label, only when the nutrient content meets the standard requirement of the "contained" claim, can the product label be declared "contained".
Natural mineral water belongs to packaged drinking water. For packaged drinking water, the characteristic indicators of the product are marked according to relevant standards, such as metasilicic acid, iodide, selenium, total dissolved solid content and the content range of main cations (K+, Na+, Ca2+, Mg2+), they are not nutritional information.
4. Q: Can nutrition claims be made on the raw materials on the outer packaging of the product? If so, is it necessary to indicate the nutritional composition table? How to label?
A: When the nutritional content of the added raw materials meets the nutritional claim requirements of GB28050-2011 "National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods", nutrition claims can be made in accordance with the standards. The description of the characteristics of the raw materials and the production process does not belong to nutrition claims, such as desalted whey powder, the description should be in accordance with the requirements of corresponding laws, regulations or standards.
5. Q: Can nutrients without NRV be claimed? Can nutrients not covered in the standard be claimed?
A: When the declared value of a certain nutrient component meets the requirements of GB28050-2011 Appendix C, it can be made a corresponding nutrition claim. Nutrient components that are not involved in the standard cannot make nutrition claims.
Business Division of Food Safety and Regulatory Compliance of Global Foodmate provides food standards & regulations research, labelling compliance consulting/Chinese label design, industry public opinion monitoring and analysis, registration services (of Infant formula, FSMP, Health food, Novel Food Ingredients, Novel Food Additives, New Varieties of Food-Related Products and Overseas manufacturers of imported food) and other comprehensive food safety solutions for domestic and overseas enterprises and institutions in food industry. Please feel free to contact us: +86 10 68869850, E-mail: global_info@foodmate.net
