In this
article of our blog series on the European regulation 1169/2011 on the
provision of food information to consumers, I want to discuss the nutrition
declaration in closer detail with reference to some actual examples.
What does the new EU regulation say about nutrition declaration?
Here are
two excerpts from the introductory statement:
- "(35 ) To facilitate the comparison of products in different package sizes, it is appropriate to retain the requirement that the mandatory nutrition declaration should refer to 100 g or 100 ml amounts and, if appropriate, to allow additional portion-based declarations. Therefore, where food is prepacked and individual portions or consumption units are identified, a nutrition declaration per portion or per consumption unit, in addition to the expression per 100 g or per 100 ml, should be allowed. ... "
- "(41) To appeal to the average consumer and to serve the informative purpose for which it is introduced, and given the current level of knowledge on the subject of nutrition, the nutrition information provided should be simple and easily understood. ..."
In the
subsequent articles the mandatory information is explained in more detail. The
following is a very abbreviated summary:
- Article 30
defines the mandatory content of the nutrition declaration. These mandatory
data are called "BIG 7" (the nutrition declaration with the
additional specification of fiber is called "BIG
8"):
"... The mandatory nutrition declaration shall include the following:
(a) energy value; and
(b) the amounts of fat, saturates, carbohydrate, sugars, protein and salt. ..." - Article 32
defines the amount to which the mandatory nutrition declaration must refer: "...Expression per 100g or per 100 ml
(1) The energy value and the amount of nutrients referred to in Article 30 (1)-(5) shall be expressed using the measurement units listed in Annex XV.
(2) The energy value and the amount of nutrients referred to in Article 30 (1)-(5) shall be expressed per 100g or per 100ml. ..." - Article 33
defines optional additional nutrition declaration per unit of consumption:
"... Expression on a per portion basis or per consumption unit.
(1) In the following cases, the energy value and the amounts of nutrients referred to in Article 30 (1)-(5) may be expressed per portion and/or per consumption unit, easily recognisable by the consumer, provided that the portion or the unit used is quantified on the label and that the number of portions or units contained in the package is stated:
(a) in addition to the form of expression per 100 g or per 100 ml referred to in Article 32 (2); ..." - Article 34
defines the presentation. " ...
(1) The particulars referred to in Article 30 (1) and (2) shall be included in
the same field of vision. They shall be presented together in a clear format
and, where appropriate, in the order of presentation provided for in Annex XV.
(2) The particulars referred to in Article 30 (1) and (2) shall be presented, if space permits, in tabular format with the numbers aligned. ..."
The nutritional information is to be presented as follows (according to Annex XV "EXPRESSION AND PRESENTATION OF NUTRITION DECLARATION " ): " ... The units of measurement to be used in the nutrition declaration for energy (kilojoules (kJ) and kilocalories (kcal)) and mass (grams (g), milligrams (mg) or micrograms (µg)) and the order of presentation of the information, as appropriate, shall be the following:"
- energy (kJ/kcal), mandatory ("BIG7")
- fat (g), mandatory ("BIG7")
of which:
- saturates (g), mandatory ("BIG7")
- mono-unsaturates (g), optional
- polyunsaturates (g), optional
- carbohydrate (g), mandatory ("BIG7")
of which:
- sugar (g), mandatory ("BIG7")
- polyols (g), optional
- starch (g), optional
- fibre (g), optional (additional information of the "BIG8")
- protein (g), mandatory ("BIG7")
- salt (g), mandatory ("BIG7") - For the
nutrition information on "salt", the regulation defines:
" ... ( 37) Since one of the objectives pursued by this Regulation is to provide a basis to the final consumer for making informed choices, it is important to ensure in this respect that the final consumer easily understands the information provided on the labelling. Therefore it is appropriate to use on the labelling the term 'salt' instead of the corresponding term of the nutrient 'sodium'. ..."
Annex I "Specific definitions" defines how the value for salt is calculated based on sodium: 'salt' means the salt equivalent content calculated using the formula: salt = sodium × 2,5".
When does the nutrition declaration become effective?
The
nutrition declaration is mandatory from 13/12/2016 onwards. If voluntary
declarations are being provided before this date, they have to correspond
to the regulation from 13/12/2014 onwards.
Product examples and their mapping in GDSN
Looking at product examples today, the format and presentation of nutritional values can be more
or less divided into three classes:
- "single-column" - the strictly mandatory declaration, i.e. the nutritional information per 100 g or 100 ml
- "double column" - in addition to the mandatory declaration, information is provided for every individual portion size
- c. "triple column" - the mandatory declaration, the portion size and an additional percentaged quantity, based on a daily intake standard (reference standards for the daily intake are listed in annex XIII of the regulation). On these products, the "1+4 model", developed by the German Federal Ministry of Food, Agriculture and Consumer Protection, is often additionally applied. This model declares the energy content and the amounts of fat, saturates, sugar and salt per serving as well as the percentage of its calories and nutrients in relation to the recommended daily intake.
Additionally,
the "Representation in the GDSN data model" shows how these
informations are transported throughout the GDSN. It also illustrates how much
interpretative and processing work is needed for a representation apart from
just the data transfer task.
Product example 1 and representation in the GDSN data model
Product example 2 and representation in the GDSN data model
Portion size is one 250ml serving.
Product example 3 and representation in the GDSN data model
Portion size is one biscuit (24g).
Product example 4 and representation in the GDSN data model
Additionally,
vitamin and trace element information are being listed as well as their
percentage in relation to the recommended daily intake.
Vitamin B1 is not specified on the GDSN UNInfoods list.
The "1+4 model" is located on the front of the packaging.
The portion size is based on a prepared serving of cereal with milk.
Product example 5 and representation in the GDSN data model
Portion size is one 25g waffle.
Product example 6 and representation in the GDSN data model
Portion size contains five biscuits (ca. 34g).
EU regulation conformity of the product examples
It is
striking that none of the considered examples is EU regulation compliant yet.
On all products the voluntary nutrition declaration according to directive
90/496/EEC in form of the "Big 8" (energy value, protein,
carbohydrates, sugar, fat, saturated fat, fiber, sodium) is supplied. However,
their sequence is changed in the new table according to the EU regulation: Fiber becomes optional and salt
is no longer listed as sodium.
Nutritional value coding in the GDSN data model
The nutritional values of the product examples were
coded following the GS1
recommended codes and attribute applications (see the following comment on salt). They therefore represent a "best practice" use
of GDSN for the nutritional information.
Yet the
example of "sodium" already indicates the band width of variations
when it comes to data management. The EU regulation compliant information would
be "salt" (code "SALTEQ"). A conversion (salt = 2,5 *
sodium) on part of the data recipient would appear to be the most pragmatic
solution. The EU regulation holds responsible whoever registers or changes the
product information though.
Many
product data will have been registered according to the GS1 recommendations for
the use of GDSN alongside the new EU regulation data. But there will also be
data suppliers who will provide product data that are EU regulation compliant,
but depart from the GS1 recommendation. Next to different applications of
attributes, codes for single nutrition values can also vary.
Here, for
example, are the possible alternatives for protein declarations:
PRO-,
protein, total; method of determination unknown or variable (the GS1
recommendation for protein coding)
Possible
other codes:
PROA,
protein, total; determined by direct analysis
PROANI,
protein from animal sources
PROCNA,
protein, total; calculated from amino
PROCNP,
protein, total; calculated from protein
PROCNT,
protein, total; calculated from total nitrogen
PROPLA,
protein from plant sources
PROTAN,
protein, animal
PROTPL,
protein, plant
Conclusion
The
new regulation ensures that the up to
now largely voluntary nutrition information on products will become obligatory
for the entire European Union. Information will be more comprehensive, uniform
and more intelligible and nutrition information will be made available for
stationary as well as online trading.
Until this is achieved by the end of the transition period in 2014 though, a lot of implementation efforts are still waiting.
Until this is achieved by the end of the transition period in 2014 though, a lot of implementation efforts are still waiting.
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