Food Labeling - III

Nutritional Information

Food labeling is a valuable tool in preventing and combating fraudulent food practices and misleading information to protect consumer health in terms of food safety and nutritional well-being. A food labeling policy includes a set of laws and guidelines establishing the information that must be provided on a food label with minimum requirements for the labeling of packaged foods in all countries. The objective is to ensure consumers have clear non-misleading information about the product identity, content, intended use, and any appropriate safety and nutrition considerations. Nonetheless, even when labeling is voluntary, guidance is needed to prevent inappropriate labels. With the wide variety of information in the marketplace, consumers may become confused about some labeling of food products, where simple, standardized, non-misleading labeling can facilitate consumer understanding so that consumers can easily recognize important information and feel confident about the product information. 
 
The hunger for more nutritional information from the consumers has been recognized as scientific evidence linking diet and health expands and deepens while social media and information technology have expanded their horizons beyond imaginations. On the other hand, another primary reason for nutrition labeling is the increased prevalence of diet-related non-communicable diseases because labeling is useful for promoting the consumption of foods containing vitamins, minerals, and protein in targeted populations easily. Hence, it is essential to address the consumer requirements through consultative processes. Through the process, various stakeholders in labeling should be able to contribute their views about the labeling policy to ensure transparency and build trust. 
 
Mandatory and Voluntary Nutrient Declarations 

A nutrient declaration label is a standardized statement or listing of the nutrient contents of a food, which should be mandatory on all packaged foods except where national circumstances would not support such declarations according to Codex recommendations. The nutritional declaration must be on all packaged foods that carry a nutrition claim, which can be presented per serving or per 100g/100ml; and if expressed per serving or a portion, the serving size or number of portions contained in the package should be stated, where serving size must be based on the food as it is sold. Nonetheless, foods that require preparation or foods commonly mixed with other ingredients or another food before being eaten (i.e., breakfast cereal mixed with milk) or information on the food as prepared can also be included in the nutrition labels. Further, the food labeling laws of the respected countries mandate that the nutrient declaration must be made by serving size, which has to have standardized predefined serving sizes or a range of serving sizes to allow flexibility based on national dietary intake data. 
 
Mandatory Nutrients 
If the nutrient declaration is applied, the nutrients that are vital to the health of the consumer and play a key role in the product purchasing decision, such nutrients must be included. The following list represents the mandatory generic nutrients, including: 

Energy value (calories), 

Amounts of protein, 

Available carbohydrate (dietary carbohydrate excluding dietary fiber), 

Total fat, 

Saturated fat, 

Sodium (or salt equivalent)

Total sugars 

Additionally, the amount of any other nutrient that is considered to be relevant for maintaining good nutritional status in national legislation or national dietary guidelines must be declared.
 
Calculations and Food Composition 

The manufacturer is directly responsible for the declared values, which must accurately reflect the contents of the product, where manufacturers are supposed to determine the energy value directly through analysis. However, there are published reference values available online that are used by the manufacturers to determine the food composition, i.e., the energy value is usually calculated by analyzing the protein, fat, and carbohydrate levels for these nutrients and then multiplying them by the conversion factors, unless a different factor is given in a Codex standard or in the Codex method of analysis for that food. 
 
Attention should be given to the food composition data used, which represent an average of the nutrient content of a particular sample of foods and ingredients, determined at a particular time that can vary substantially between different batches and brands. Such differences can result from a number of factors, including changes in season, processing practices, and ingredient sources, where a manufacturer should carefully evaluate the accuracy, completeness, and relevance of the results for their purposes before relying on calculated nutritional values generated by food databases. On such occasions, manufacturers should obtain expert advice in developing their nutrition labels.
 
Nutrient Reference Values 

When making the nutrient declaration, information on protein and additional nutrients may be expressed as percentages of the Nutrient Reference Values (NRV) where an NRV has been established. “NRVs are a set of numerical values that are based on scientific data associated with nutrient requirements or associated with the reduction in the risk of diet-related non-communicable diseases,” therefore, NRVs are derived for the purposes of nutrient declaration and relevant claims on food labels. The nutrients within the nutrient declaration can be presented as the % NRV, where the % NRV provides a quick overview of the nutrient levels in food. Thus, a consumer can use the % NRV to compare two different food products to help choose foods that are higher in the nutrients they desire and lower in the nutrients they want to reduce or avoid. For optional nutrients, values <5% NRV should not be declared. 
 
In addition, Codex has defined Nutrient Reference Values – Noncommunicable Disease (NRVs-NCD), which refer to NRVs that are based on levels of nutrients associated with the reduction in the risk of diet-related non-communicable diseases, not including nutrient deficiency diseases or disorders. Three NRVs-NCD have been established to date, and others are under discussions, such as i.e., EPA and DHA Long chain Omega 3 fatty acids. The current intake levels are: 

Saturated fatty acids at 20 g – intake levels not to exceed 

Sodium at 2000 mg – intake levels not to exceed

Potassium at 3 500 mg – intake levels to achieve 

 
Nutrient declarations are usually presented in a standard format on the back of the package or side of the package. On the contrary, several countries have established their own NRVs based on recommendations that have been developed using data from their own population, such as the Daily Value (DV) adopted in the USA and Canada or Daily Intake (DI) in Australia. It is recommended that expert advice be sought when setting country-specific NRVs for national labels.
 
Nutrient Claims 

Besides the nutrient declaration, “Nutrition Claims” is any representation which states, suggests, or implies that a food has particular nutritional properties, where nutrient claims can be made on the food label on a voluntary basis. The use of nutrient claims on the food label is under the discretion of the food company as long as the food meets relevant criteria, as outlined in national food labeling legislation in the country where the product is being sold. Thus, there must be defined criteria within food labeling legislation to prevent misleading or false claims. Typically, energy, protein, carbohydrate, and fat and components thereof, fiber, sodium, and vitamins and minerals are the only permitted criteria for nutrition claims those relating to which Nutrient Reference Values (NRVs) established in the Codex Guidelines for Nutrition Labelling (CAC/GL 2 – 1985). Nutrition claims can be categorized as either nutrient content or comparative nutrient claims.
 
Front of Package Nutrition Labelling 

Front of Package (FOP) systems and symbols summarize key nutritional aspects and characteristics of food products and often integrate characteristics of traditional nutrition labels, as well as nutrition and health claims, which is typically found on a product’s principal display panel, or may also be elsewhere on the food label. The FOP label is easily seen in the market and attracts consumers’ attention because consumers often need more guidance for selecting foods for a healthy diet than is given by nutrient declarations, ingredient lists, and claims. Nonetheless, an extensive array of researches outlined that simplified labels promote more accurate evaluations of foods by consumers. 
 
According to the United States Institute of Medicine (IOM, 2010), there are different recognized FOP systems and symbols in use internationally at the time, including:
 

Nutrient-specific systems – These systems are either that display the amount per serving of calories or select nutrients from the nutrient declaration on the front of the pack or symbols based on nutrition or health claim criteria.

 

Summary indicator systems – These are symbols, icons, or scores that provide summary information about the nutrient content of food, but they offer no specific nutrient content information to consumers. Summary indicator systems attempt to assess the overall healthiness of food using either thresholds or algorithms. Threshold-based systems typically establish maximum levels for nutrients to limit and minimum levels for nutrients or food components to encourage to judge whether a product qualifies for a summary indicator symbol. Those are algorithm-based systems award points for the presence of nutrients or food components to encourage and subtract them for the presence of nutrients to limit to arrive at a final score that is used as the summary indicator symbol.

 

Food group information systems – These include symbols that indicate that a food group (such as fruit and vegetables) or a food ingredient important to the diet (such as whole grains) is present in a food product. 

 

The prominent examples for such systems; In Norway, Sweden, Finland, and Iceland, a regional “keyhole” FOP has been used for several years. Australia and New Zealand have released a “healthy start” FOP recently. Nonetheless, the United Kingdom has developed a “traffic light” FOP over several years. In contrast, in Europe and the USA, governments have begun to pursue strategies to standardize voluntary FOP systems with government-developed nutrient profiling criteria.
 
Health Claims 
There are no specific health claims outlined by Codex for the use on labels or their criteria, where all the permitted health claims and their criteria are defined and approved by the respective national authority in each country to avoid false, misleading, and unsubstantiated claims. Any product can only bear a health claim if the claim is approved in the country where the product is being sold, and a health claim should only be presented for approval if the claim is substantiated with current relevant scientific evidence and should be re-evaluated when new knowledge becomes available. It is recommended to seek expert advice when establishing a framework for health claim substantiation. Generally, substantiation of a health claim involves a systematic review of the scientific evidence, which includes: 

Identification of the proposed relationship between the food or food constituent and the health effect; 

Identification of appropriate valid measurements for the food or food constituent and for the health effect; 

Identification and categorization of all the relevant scientific data; 

Assessment of quality and interpretation of each relevant scientific study; 

Evaluation of the totality of the available relevant scientific data (published and unpublished when available), weigh the evidence across studies, and determine if and under what circumstances a claimed relationship is substantiated. 
 

Moreover, the evidence used to substantiate a health claim should be based on well-designed human interventions that demonstrate a consistent association between the food or food constituent and the health effect to be claimed when consuming a reasonable amount of the given food or food constituents. Other types of studies are generally not sufficient to substantiate a health claim on their own. The systematic review should be carried out by national authorities, or the systematic review should be conducted by industry applicants and submitted to national authorities for review and approval. Both approaches benefit from consulting expert advice on the specific food and health relationship, where several countries have published scientific and technical guidance on how to prepare a submission for health claim approval. When approving a health claim for use in the marketplace, it is important to consider if the amount of the food or food constituent exposes the consumer to health risks or known interactions that may pose health risks and/or exceeds appropriate upper levels of intake for the food or other constituents. Exposure assessments should be conducted and be based on an evaluation of the distribution of usual total daily intakes for the general population and, where relevant, for vulnerable population sub-groups. 

Reference:

http://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FMeetings%252FCX-714-44%252FCRDs%252Ffl44_crd06x.pdf
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