The applicable standards for the pre-packaged food nutrition labeling are the “Food Safety National Standards General Principles for Nutritional Labelling of Pre-packaged Foods” (GB28050). The applicable standard for the labeling of pre-packaged special dietary food labels is “Food Safety National Standard Pre-packaged Special Dietary Food Labels”. 》(GB13432). Below we separately explain the review methods and key points of the two nutrition labels.
The pre-packaged food nutrition label consists of three parts: nutrient composition table, nutrition claim, and nutrient function claim. In addition to the following product categories exempt from nutrition labeling, other products require mandatory labeling of nutrition labels. Products that need to be labeled with a nutrition label are required to be labeled. The nutritional claims and functional claims can be selected by the company according to the actual situation.
The following will combine the judicial precedents of the Food Safety Law, law enforcement practices, and review procedures to explain the key points of food nutrition labeling and the common legal issues in practice.
1、Review whether the nutrition label is mandatory
According to the provisions of Article 7 of GB28050 and the explanation of relevant questions and answers, the types of prepackaged foods exempt from labeling nutrition labels are as follows:
(1) Fresh food product
(2) Drinks and alcohols with an alcohol content ≥0.5%
(3) Foods with a total package surface area of ≤100cm2 or a maximum surface area of ≤20cm2
(4) Deli Food
(5) Packed drinking water
(6) Pre-packaged foods with a daily consumption of ≤10g or 10mL
(7) Pre-packaged foods that may not need to belabeled with nutrition labels as stipulated by other laws and regulations
2、 review the comprehensiveness and accuracy of nutrition labels
The correspondence of the nutrition label means that the content of the nutrition label should correspond to the ingredient list in the prepackaged food label. The nutrition label promises to contain a certain nutrient ingredient, which should be able to find the corresponding ingredients in the food ingredient list.
The comprehensiveness of a nutrition label refers to the complete indication of all mandatory labeling of the nutrition label. The mandatory labeling of the nutrition label includes the mandatory labeling content directly stipulated by GB28050 and the matter that must be marked on the nutrition label because the food producer has implemented a labeling behavior, such as the content claim of a certain nutrient.
(1) It is not applicable to determine whether the marked value is accurate only by calculation
(2) Be cautious to the supply of nutrients other than protein, fat and carbohydrates
(3) Errors are not allowed
(4) Other factors that need to be considered to indicate the accuracy of the data
(5) Pay attention to the matching with other standards
3、nutrient reference value and its usage
Before you get a reference to nutrients and how to use them, you must first understand the differences and connections between nutrients and nutrients.
In addition, label reviewers should note:
Although the energy conversion coefficient of erythritol and other sugar alcohols (0kJ/g of erythritol and 10kJ/g of other sugar alcohols) is given in the GB28050 related question and answer, the conversion factor is only a suggestion.
4、 the treatment of other problems marked by nutrition labels
GB28050 Appendix B provides a total of six nutrition labeling forms, namely: 1, only the energy and core nutrient format; 2, the format of mark more nutrients; 3, attach a foreign language format; 4, horizontal row format; 5, text format; 6, with a nutrition claim and/or nutrient function claim format.
