This is the final part of issues related to content claims, comparative claims and nutrition claims.

10. Q: Does the “sugar-free” claim meet the requirements of “carbohydrates” or “sugar”?

A: The "sugar-free" claim is a claim on sugar. Sugars include monosaccharides and disaccharides, which are a kind of carbohydrates. Therefore, when the carbohydrate content is "0", the sugar content must be "0". When carbohydrates are marked as "0" in the nutrition fact of the product, it meets the conditions of the "sugar-free" claim, and the enterprise can make a corresponding claim. There is no need to compulsorily indicate the sugar content in the nutrition fact. If the carbohydrate content is not 0 and the sugar content is 0, a “sugar-free” claim can also be made. In this case, the sugar content needs to be declared separately.

11. Q: This standard stipulates that if you claim "zero or low cholesterol", you must meet "low saturated fat". If milk is processed to remove cholesterol while retaining its own fat, can it be claimed as "zero or low cholesterol"?

A: This standard has clearly stipulated that when claiming "no cholesterol" or "low cholesterol", it should meet the claimed content requirements and restrictive conditions of low saturated fat at the same time. Therefore, when making the above claim, it should be implemented in accordance with the standard.

12. Q: Does the unused content claim terms such as "Enhance calcium, iron and zinc" on the package need to meet the requirements and conditions of content claim?

A: "Enhance" does not belong to the category of nutrition claims.

13. Q: Please clarify whether the Trans fatty acid content of product is far below 0.3% can be claimed on the product packaging as "zero Trans-fat" or "100% Trans-fat free"? What are the specific requirements for the claimed location?

A: According to the provisions of Table C.1 of this standard, for the flexibility and diversity of label expression, when the content of Trans fatty acids in food is ≤0.3g/100g (solid) or 100mL (liquid), it can be claimed as Trans fatty acids "free" or "no" trans fatty acids. Table C.2 of this standard stipulates that when the nutrient content of the food meets the claim conditions of "not contain" or "no", "zero (0)", “not have”, "100% does not contain" and "0%" can also be used.

The B.2.6 of this standard lists the nutrition label format with nutrition claims and/or nutrition component function claims, which stipulates that nutrition claims and nutrition component function claims can be placed in any position on the label, but their font size shall not be larger than the food name and trademark.

14. Q: When making a content claim, when the condition of "no" or "free" is reached, can it only be claimed as "low"? For example, if the lactose content in dairy products is ≤0.5g/100g (mL), can the product packaging label be marked with "low lactose"?

A: According to the provisions in Appendix C of this standard, when the lactose content in dairy products is less than or equal to 2g/100g (mL), the low lactose can be claimed, and when the lactose content is less than or equal to 0.5g/100g (mL), the non-lactose can be claimed. According to the above claimed content requirements, if the lactose content in the product is ≤0.5g/100g (mL), the company can claim "low lactose" or "lactose free" according to product characteristics and design concepts, and both claims meet the standard requirements.

From October 12 to 14, we discuss some issues related to content claims, comparative claims and nutrition claims, which food businesses could have during the food processing. Tomorrow we will move on some issues related to exemption labeling on Nutrition Label. Please keep following us.

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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. 

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