A label is typically the first element that consumers consider before buying a food supplement.
It is always a challenge knowing how to prepare a correct label for a food supplement product. It must be in line with all the regulatory requirements, as well as attractive to a consumer—all without drawing any negative attention from regulators.
These products must respect specific labeling requirements laid down in a European Union (EU) regulatory directive (Directive 2002/46/EC) on food supplements.
As food supplements are classified as food products in the EU, the provisions on food labeling stipulated in general food law must also be respected.
2014 was the key year of application for Regulation (EU) No 1169/2011 on the provision of food information to consumers, which is applicable to all food products. What we used to generally call “food labeling" in the EU is therefore now called “food information to consumers."
New provisions were introduced with this regulation, among other elements on legibility, mandatory font size, allergen labeling, nano-materials, distance communication and the nutrition declaration. The regulation for the first time clearly stipulates additional warning particulars for foods other than beverages where caffeine is added with a physiological purpose.
Food supplements are explicitly excluded from the mandatory nutrition declaration since specific declaration rules for them are already provided in Directive 2002/46/EC on food supplements. These rules specify that the amount of nutrients or substances with a nutritional or physiological effect present in the product must be declared on the labeling in numerical form, per portion of the product as recommended for daily consumption, and also expressed as a percentage of the reference values.
The regulation (EU) No 1169/2011 on the provision of food information to consumers has provided for a number of transitional measures.
However, many questions have arisen regarding when and how to apply the new rules. The regulation, although adopted in 2011, foresees a record number of Commission-implementing acts, delegated acts and reports, over the next five years for the application of certain requirements. It’s therefore crucial to stay well informed, in order to ensure that your food supplement labels continue to meet the applicable legal requirements.
Katarina Wagner is manager of regulatory affairs, Europe & Middle East Africa, EAS Strategies. EAS Strategies will present on “Labelling food supplements for the EU market" at the Center Stage at the Vitafoods Europe Conference on May 12, 2016.
