Source: China Pharmaceutical News

Nutritional content labeling

The enterprise may determine the labeled value by calculating raw material, testing product, and considering nutrition and permissible error of the component. The accuracy of the labeled value of the nutrition should be evaluated based on the method (calculation or detection method) for the company to determine the labeled value.

During the evaluation, in addition to the permissible error range of the energy and nutritional content specified in the Standard, it should also be noted that the labeled nutritional value on the nutrition label is “authentic and objective”, which is stated in the basic requirements of the Standard. Enterprises should determine the labeled value by taking various factors into account that may affect the fluctuation of the nutritional composition on a true and objective basis, rather than “make up” or “alter” the value in order to fit the permissible error. For example, the Standard specifies the measured values of the fat and others should be less than or equal to labeled value of 120% without a lower limit, and the fat content of a certain product fluctuates around 2g/100g. It’s against the basic requirements of "authenticity and objectivity" in the Standard when an enterprise marks 5g /100g in order to ensure its content range falls within the permissible error of the labeled value.

Besides, whether the product is qualified is not determined simply by the labeled nutritional value and the allowable error. If required in the standards of the product, nutritional content should meet both the requirements of the product standard and the allowable error range specified by the nutrition labeling standard. For example, the National Food Safety Standard Sterilized Milk (GB25190-2010) stipulates that the protein content in cow’s milk should be greater than or equal to 2.9g/100g. If the labeled protein value on the product’s nutrition label is 3.0g/100g, whether the product meets the national standard requirements should mainly depend on whether the actual protein content is greater than or equal to 2.9g/100g.

Nutrition fact format

Nutrition fact should be presented in the form of a “box” (except in exceptional circumstances), which can be of any size and perpendicular to the baseline of the product packaging. Nutrition facts consist of five basic elements: the head (i.e. “nutrition facts”), the name and content of the nutritional components (including value and unit), NRV%, the box (i.e. in the tabular or relevant form).Standard Table 1 lists the name, sequence, unit, rounding interval, and “0” threshold value, etc. of mandatory and optionally labeled nutritional contents in the nutrition facts. Nutrition facts labeling shall comply with the requirements of Standard Table 1.

In addition, six basic formats are recommended in Appendix B of this Standard for reference in order to standardize food nutrition labeling and make it easier for consumers to remember and compare. On the basis of compliance with the basic format requirements and guarantee not to mislead consumers, the enterprise may make appropriate adjustments in the layout design, including but not limited to: adjust the text formatting (left-aligned, center, etc.), background and table color, or add more inner table borders, etc. for aesthetic reasons or for the convenience of consumers to observe.

Optional labeled content

The optional labeling content specified in the Standard falls into three parts. The first is that in addition to the mandatory labeling content, the other components in Table 1 can be selected for the nutrition facts. The second is the nutrition claim, which is the content or comparison claim for a certain nutritional component. The claim should be made to ensure that the labeled content value meets the corresponding requirements in Appendix C of the Standard. The third is functional claim of the nutritional ingredient, that is, to claim a nutritional ingredient by functional claim standard phrases of one or more nutritional ingredients in Appendix D of the Standard. The claim should also ensure that the labeled content value meets the requirements and conditions of content or comparison claim. It should be also noted that no correction, deletion, addition, or merging shall be made on functional claim phrases.