20. Q: When companies voluntarily mark nutrition labels on pre-packaged tea products, please clarify whether the tea product is tested for tea soup or tea during the nutrient composition test? Or are both methods possible?

A: Both methods are fine. In order to avoid ambiguity in actual operation, companies can add relevant instructions in the vicinity of the nutrition label to clarify which method is used.

21. Q: GB 28050-2011 and the standard Q&A (revised edition) list products that can be exempted from labeling nutrition labels, but different departments have different understandings. For example, Chinese wolfberry, Can it be classified as a substitute tea with a small consumption ratio or dry products without other ingredients? Do such foods need to be labeled with nutrition labels?

A: Chinese wolfberry can be exempted from nutrition labeling

22. Q: Gum-based candies are foods that are exempted from mandatory labeling of nutrition labels. Sugar-free gum-based candies are a type of gum-based candies in the GB/T 23823-2009 "Classification of Candy". If sugar-free chewing gum is indicated on the product label, does it need to declare a nutrition label ?

A: Sugar-free chewing gum is a nutrition claim for sugar and should be marked with a nutrition label.

23. Q: GB 28050-2011 Q&A (revised edition) stipulates that "the amount of carbohydrates in food can be calculated by subtraction or addition". Foods with different characteristics should choose different methods (addition or subtraction) to determine the content of carbohydrates. For beverages with 0 protein and fat, it is advisable to use addition to calculate the carbohydrate content. At the same time, the carbohydrate content calculated by different methods is also different.

Please list separately the applicable scope of addition and subtraction and the situations where the calculation method is not suitable. For example, for products with a fermentation process, because the fermentation process will decompose carbohydrates and proteins, the protein content and carbohydrate content of the final product are very different from the raw materials. Can the calculation method not be used in this case?

A: The amount of carbohydrates in food can be calculated by addition or subtraction. The company should choose a suitable method according to the characteristics of the product and be responsible for the authenticity of the data.

24. Q: Dietary fiber is not digested and absorbed. It is a low-energy food. Is the energy calculation coefficient "8" too high? There is a product with a dietary fiber content of 90%, almost no protein, fat, and available carbohydrates, but its energy is calculated to far exceed 170kJ/100g. However, this standard stipulates that products with energy less than 170kJ/100g are low energy food, inconsistent with product characteristics

A: Foods rich in dietary fiber and low-energy foods are two concepts and cannot be simply equated. Nutrition claims should be made with reference to this standard.

Recommend article:
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (1)
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (2)
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (3)
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (4)

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