Food Labeling

Development of Food Label Requirements

The first front-of-package (FOP) nutrition rating system introduced more than 30 odd years ago, followed by a variety of systems. American Heart Association (AHA) created the Heart Guide symbol in 1987, which categorized foods using a single symbol that would indicate whether a product was “heart-friendly” or not to the end-user, followed by various innovative systems and symbols in food labeling.  Since then, systems have been developed and improved by food manufacturers, retailers, non-industry experts, non-profit organizations, industry and non-industry consortia, and government agencies.
 
Up until the late 1960s, there was little information on food labels to identify the nutrient content of the food. There are records for the calorie or sodium content included on some food labels from 1941 to 1966 when information on those foods was considered by the Food and Drug Administration (FDA) to be for “special dietary uses.” Such foods are intended to meet particular dietary needs caused by physical, pathological, or other conditions.
 
Scientific knowledge about the relationship between diet and health proliferated after 1973. As a result, consumers wanted to have more information on food labels, particularly on the labels of processed and packaged foods. Food manufacturers were eager to respond to the consumer interest and did so in a variety of ways. Often through the use of an assortment of new, undefined claims on product labels that attempted to state or imply something about the unique value of the food, such as “extremely low in saturated fat,” to catch consumers’ attention. 
 

Food labeling is a valuable tool to protect consumer health in terms of food safety and nutritional well-being and prevent fraudulent practices and misleading information. Consumers may become confused about labeling some food products with the wide variety of information in the marketplace. Simple, standardized, non-misleading labeling can facilitate consumer understanding. Thus, consumers are able to easily recognize important information and feel confident about the product information. Harmonization of food labels is desirable from the perspective of food producers as well as consumers. Codex labeling texts provide a useful resource to harmonize national labeling requirements or to create such provisions if they do not exist. Besides, most of the goals of front-of-package rating systems and symbols are related to helping consumers make more nutritious food choices, given an environment in which the impact of diet on health is of increasing concern.
 
The World Trade Organization is responsible for two agreements that are relevant to food labeling to protect and promote human health: the Agreement on Technical Barriers to Trade (TBT) and the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS). Developing an effective food labeling policy requires scientific expertise in nutrition, food science, and food technology. Legal expertise and economic analysis are needed as well. Finally, consumer and communication specialists should be involved in developing labels to ensure that the labels are understood and useful for the people for whom labels are intended, the ordinary citizen.
 
There are many components of a food label that aim to protect consumers from food fraud and promote the health of consumers. Codex recommends that key types of information about the exact nature and characteristics of packaged foods be mandatory on labels. Legislation can give authority to address fraudulent practices in food labeling by outlining provisions requiring food labeling information. The components discussed below indicate the minimum information which should be mandatory on a food package label. Revision of national legislation may be necessary to achieve this standard of labeling.
 
Food Labelling Policy

A food labeling policy is a set of laws and guidelines establishing the information that must be provided on a food label. There should be minimum requirements for labeling packaged foods in all countries to ensure that consumers have clear non-misleading details on the product identity, content, intended use, and appropriate safety and nutrition considerations. These regulations and guidance are required even when labeling is voluntary to prevent inappropriate labels. Hence, a food label policy should include strategies to assist producers in complying with labeling rules and education programs to help consumers to understand and use labels. Further, said the policy should define the various agencies and organizations, which assigned to be responsible for implementing the policy and provide resources to support the policy. The various stakeholders in labeling should be able to contribute their views about the labeling policy through consultative processes to ensure transparency and build trust.
 
Food Identity
Information on the identity of the food must be on the label to help consumers exactly understand what they are purchasing, which must include the food name, the quantity of food, and contact information for the food manufacturer, country of origin, and lot number.
 
Ingredient Lists

The ingredients list is designed to inform consumers of the substances used to make the food product, except for single-ingredient foods (e.g., milk, salt). Thus, a list of ingredients with specific names is recommended to be mandatory on the food label. Nonetheless, suppose a food product is dehydrated or condensed. In that case, the ingredients may be listed in order of proportion in the reconstituted product, and a statement “ingredients of the product when prepared in accordance with the directions on the label” must be included. Besides, if a general class name can be more informative, they may be used in the ingredients list; for example, ‘sugar’ can be used to describe all types of sucrose or ‘milk protein’ to describe milk products containing at least 50% protein.
 
Quantitative Ingredient Declaration (QUID)
It may be necessary to state the quantity of an ingredient on the label, in certain circumstances, which corresponds to the quantity of the ingredient(s) in the finished product, where the quantity must be declared in percentage terms and should appear in or next to the name of the food or be in the list of ingredients, is known as quantitative ingredient declaration or QUID. The QUID is designed to help consumers to compare the composition of similar products on ingredients that are likely to influence their choice.
The QUID is recommended on the label in the following situations:

• If the ingredient is included in the name of the food, such as ‘meat pastry’ where the meat must be quantified;
• If the ingredient is emphasized in words, pictures, or graphics such as ‘with cheese’;
• If the ingredient is not included in the name of the food or emphasized on the label but is essential to characterize the food and is expected to be present in the food by consumers, the content of the expected ingredient must be quantified.

Food Additives
According to the Codex definition, “any substance that is not normally consumed as a food by itself and not normally used as a typical ingredient of the food, whether or not it has nutritive value, the intentional addition of which to food for a technological (including organoleptic) purpose in the manufacture, processing, preparation, treatment, packing, packaging, transport or holding of such food results, or maybe reasonably expected to result (directly or indirectly), in it or its by-products becoming a component of or otherwise affecting the characteristics of such foods. However, the term does not include contaminants or substances added to food for maintaining or improving nutritional qualities.
 
An international expert scientific committee administered jointly by the FAO and the WHO called as Joint FAO/WHO Expert Committee on Food Additives (JECFA) evaluates the safety and develops the specifications of food additives, and the JECFA provides its scientific advice answering to requests from the Codex Committee on Food Additives (CCFA). Nonetheless, the CCFA defines the technological need for any given food additive. Once the additive received the JECFA’s safety evaluation, then CCFA defines the levels of use for food additives and develops the general standard as the authoritative source on food additives that are accepted internationally. Further, the CCFA collaborates with the relevant Codex commodity committees on use levels, categories, and technological needs.
 
Labeling Allergenic Ingredients

Food allergies are the inappropriate immune responses generated due to constituents in the foods that are mostly protein substances causing allergic reactions when the same food is eaten again, where some allergic reactions may be severe or even fatal. Thus, hypersensitive consumers may not be able to recognize allergenic foods without appropriate information when they are found in mixed food products. Further, the technical terms used to describe ingredients of processed foods may not be understood by consumers. Hence, if a food contains ingredients that are made from allergenic raw materials, the source of the ingredients should be stated in simple language. Although more than 200 allergens have been identified, regulatory agencies generally agree on the common foods that must be included in the allergy lists.
The major categories of allergenic foods that should be listed on the label according to the Codex General Standard on Labelling of Prepackaged Food are:

• Cereals containing gluten; that is, wheat, rye, barley, oats, split or their hybridized strains and products of these;
• Crustacea and products of these;
• Eggs and egg products;
• Fish and fish products;
• Peanuts, soybeans, and products of these;
• Milk and milk products (lactose included); 
• Tree nuts and nut products;
• Sulphite in concentrations of 10 mg/kg or more.

In addition, spices such as mustard, sesame, and celery, as well as seeds like lupine, are also considered as allergenic foods in some of the major food legislations in the current context.    

The rationale for including specific foods on allergen lists and for exempting other allergenic foods may vary, where each country should assess the risk of food allergies in their national population when developing the list of allergens to be labeled. Nonetheless, precautionary labels should be applied where necessary because different food products may be manufactured in the same location, and traces of allergenic foods can appear in other foods. For example, some products contain a warning “May contain milk products” “Manufactured in a plant processing peanuts.”

 
References
http://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXS%2B1-1985%252FCXS_001e.pdf
http://www.fao.org/fao-who-codexalimentarius/about-codex/science/en/
https://www.lawinsider.com/documents/egls501qR8X
https://gmdewald.medium.com/the-background-of-design-in-europe-during-world-war-ii-f624778acf58
https://www.nap.edu/read/12957/chapter/4
https://www.nap.edu/read/12957/chapter/6
https://www.un.org/ldcportal/sps-agreement-the-application-of-sanitary-phytosanitary-measures/