Today, we continue looking at some issues related to content claims, comparative claims and nutrition claims

6. Q: How to understand that "reference food should be a food of the same or the same category that is familiar and easy for consumers to understand"? Regarding salt reduction claims, what are the rules for reference food selection? For example, soy sauce, a fermented product, different soy sauces produced by different manufacturers may differ greatly in their nutrient content, such as sodium, due to the differences in raw materials used and fermentation processes. It is difficult for large companies to select reference foods reasonably and accurately. Please give a more detailed explanation.

A: Reference foods refer to foods of the same or the same category that are familiar and easy to understand by consumers. When making comparison claims, companies can choose reference foods on their own, and should consider the requirements when choosing:

1) It is the same group (or same category) or similar food with the food being compared;

2) The public is familiar with it, and the form of existence can be easily and clearly identified;

3) The compared ingredients can represent the basic level of the same group (or same category) or similar foods, instead of artificially adding or reducing the content of a certain ingredient.

Example 1: You cannot use skimmed milk as a reference food to compare the fat content of other milks.

Example 2: "Ordinary milk" can be used as a reference food claiming "Vitamin D-added milk". In order to reflect the true characteristics of the product while avoiding suspected unfair competition, companies can use their own commercially available similar products as reference foods for nutrition claims.

7. Q: When all the requirements of this standard are met, can nutrition labels in the form of graphics be added to other positions on the same label?

A: In accordance with the provisions of this standard, after the enterprise correctly and normatively declares the nutrition information in the nutrition fact, it is allowed to use graphics or other methods to explain the nutrition label without violating relevant laws and standards, such as the explanation of nutrition composition numbers, the explanation of the concept of nutrient reference value (NRV), the meaning of the percentage of nutrient reference value (NRV%), etc., which facilitate consumers to better understand.

8. Q: According to the provisions of Table C.1 of this standard, when claiming vitamins or minerals as "rich", only one of the following three conditions must be met:

1) ≥30% NRV/100g;

2) ≥15% NRV/100mL;

3) ≥10% NRV/420kJ.

When making a corresponding content claim on the label, in order to facilitate consumers’ understanding, should the corresponding remarks be added to clarify what conditions are met for the content claim, such as "Nutrition claim is only calculated per 100g", "Nutrition claim is only calculated per 100mL", "Nutrition claim is only calculated per 420kJ"? Can you add examples for reference?

A: When a product meets one of the above three conditions for nutrition claim, if it does not clearly indicate which conditions are met and it is easy to cause ambiguity, the company can voluntarily adopt the form of adding corresponding instructions on the adjacent parts of the nutrition label to further clarify the requirements, Such as "Nutrition claim is only calculated per 100g", "Nutrition claim is only calculated per 100mL", "Nutrition claim is only calculated per 420kJ", etc.

9. Q: Does the nutrient function claim permitted by this standard violate Article 71 of the Food Safety Law?

A: No. Nutrient function claims are claims that certain nutrients can maintain the normal growth, development and normal physiological functions of the human body. From this definition, it can be seen that this type of claim does not involve disease prevention and treatment functions. Therefore, it does not violate Article 71 of the Food Safety Law.

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Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (1)

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