30. Q: This standard stipulates that the actual measured value of fat is ≤120% of the label value, but there is no lower limit. If the fat label is 10g/100g, the actual value is only 1g/100g, is it qualified?

A: 3.1 of the basic requirements of clause 3 of this standard stipulates that “any nutritional information indicated on the nutrition label of prepackaged food shall be true and objective, shall not indicate false information, and shall not exaggerate the nutritional or other effects of the product”; 3.4 stipulates, “Food nutrient content should be marked with specific values, which can be obtained through raw material calculations or product testing". No matter which method is adopted, food manufacturers should ensure that the information on the nutrition labels of their products is true and objective to protect consumers' right to know.

In addition, considering the fluctuations in the nutrient content of food due to various factors such as raw materials, processing, shelf life, etc., the standard also stipulates the allowable error range of energy and nutrient content. During the product shelf life, the allowable error range should meet the requirements of Table 2 in the standard.

31. Q: For products with many ingredients and unstable source of raw materials, the fluctuation of the final energy and each nutrient value will exceed the allowable error range of the label value, how to deal with it? The index of fermented food varies greatly and sometimes exceeds the allowable error. How to deal with it?

A: Enterprises should standardize management, use stable quality raw materials, control process parameters, and maintain product quality stability; at the same time, enterprises should increase testing batches, accumulate multiple batches of nutrient testing data, and then follow the requirements of this standard. The allowable error range of the nutrient label value shall be reasonably indicated, and the nutrient shall be controlled within the allowable error range.

32. Q: Enterprises label nutrition labels according to the calculation method, but the results exceed the error allowed by the standard according to market spot check. How to deal with it?

A: The enterprise should determine the value indicated on the label in accordance with the method in Article 53 of this standard Q&A (revised edition) on the accuracy of the indicated value. When judging the accuracy of the value indicated on the nutrition label, the method used by the enterprise to determine the label value should be used as the basis. If there is any non-compliance after random inspection, the company should confirm whether it is because the method of determining the label value is improper, or because the method of determining the label value of the nutrition label is not used as the basis when determining the accuracy of the nutrition label value, or the product itself is non-compliant, etc., take appropriate measures.


33. Q: QB/T 2438-2006 "Plant Protein Drink Almond Dew" requires a protein content greater than or equal to 0.5%, and SB/T 10015-2008 "Frozen Drink Ice Cream" requires 0.4% of combined ice cream protein. According to the provisions of this standard, if the protein content is less than or equal to 0.5%, it should be marked as 0 in the nutrition fact. How to deal with this situation?

A: According to the standard "0" limit value label should be marked as 0, but the actual content should meet the requirements of the corresponding product standards.

34. Q: When marking the value, should I round up first or judge the 0 limit first?

A: You should first round up according to the rounding interval and then judge the 0 limit value.

35. Q: For nutrients at the 0 limit, such as protein content of 0.39, should it be calculated as 0 or 0.3 when calculating energy? Or both is OK?

A: The company decides on its own. The value on the same label can either come from calculations and/or from testing. The company can decide on its own according to the principle of identification safety.

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)
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (5)
Q&A | National Food Safety Standards, General Principles of Nutrition Labeling of Prepackaged Foods (6)

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