On September 26, 2021, the Secretariat of the National Food Safety Standards Review Committee issued a letter on soliciting opinions on the National Food Safety Standard General Rules for the Nutrition Labeling of Prepackaged Foods (Draft for Comments). Related units were required to provide feedback before November 21, 2021. Antion compared the contents of the Draft with the current version, and analyzed and interpreted its main changes and impacts as follows:
1. Supplemented the scope of application
Compared with the current version, the nutrition labeling of prepackaged foods that were directly provided to consumers was supplemented, and it was clearly stated that the nutrition labeling of prepackaged foods and food storage and transportation packages that were not directly provided to consumers should be labeled in accordance with the standard, which can effectively solve the problem that enterprises do not know how to mark nutrition labeling of prepackaged foods and storage and transportation packages that were not directly provided to consumers.
2. Clarified the scope of sugar
The Draft followed the international basic concept of sugar, and pointed out that the sugar marked on nutrition labeling should be the sum of monosaccharides and disaccharides (not including polyol).
3. Clarified the requirements for imported prepackaged foods
Compared with the previous version of the Draft, this time it was clearly stipulated that the contents of nutrition labeling of imported prepackaged foods should comply with the provisions of the standard.
4. The mandatory labelingitems were adjusted from "1+4" to "1+6"
Compared with the current version, saturated fat (or saturated fatty acid) and sugar were supplemented to the mandatory labeling contents. Antion recommends that enterprises pay close attention to the revision of the standard and do a good job in advance.
5. Practically implemented the concept of Great Health
The new mandatory warning word "children and adolescents should cautiously choose high fat, salt and sugar foods" was in line with the "three reductions" policy advocated by the National Healthy Lifestyle Diet Action, namely: reducing salt, reducing oil, and reducing sugar. In the optional labeling items, it was also proposed that the pagoda graphics and core recommendations of the "Chinese Resident Dietary Guidelines" can be used to promote reasonable diets and reduce the intake of oil, salt and sugar, which reflects national emphasis on the Healthy China Rational Diet Action and National Nutrition Plan.
6. Supplemented the option to label by serving and clarified consumption method
The serving reference value refers to the recommended reference mass or volume of each serving of food when the nutrition information was labeled as "serving", which can gradually guide enterprises and the market to regulate the use of the expression "serving". Therefore, when making nutrition information by "serving" as a unit, enterprises can refer to the serving reference values of prepackaged foods in Appendix E. The recommended food categories in Appendix E were adjusted from 19 categories in the previous version of Draft to 18 categories. This time, the biscuits and cereal bars with the same serving reference value of 30g per serving were combined into the same category.
7. Supplemented the descriptions of food energy, sodium and fat to the optional labeling items
For example, calories, kilocalories, calories, salt and oil. The expression "low salt" in the previous version of Draft was deleted, and the word "oil" that can be used when describing fat content was supplemented, enriching enterprises' choice and diversity in labeling.
8. Modified and supplemented the labeling and expression of nutritional components
Antion summarized the main changes including:
①The content of Article 31 of GB 28050-2011 Q&A (revision) was supplemented to emphasize that when labeling multiple nutrients, appropriate forms should be adopted to prominently label mandatory labeling items, including increasing the font size, changing the font (overstriking, black, italic), changing the color (the color of font or background).
②Supplemented the way to obtain the clear labelled value, which can be obtained according to the currently valid national standard method, or calculated according to the ingredient composition of formula, using the "Chinese Food Component Table" or other credible data sources.
③The content of Article 33 of GB 28050-2011 Q&A (revision) was supplemented to clarify that when the contents of nutritional components were labeled by "serving" as a unit, the "0" threshold value should meet the requirements of "0" threshold value per 100g or per 100mL. When "0" is marked, it can also be marked as "0.0" or "0.00" according to the rounding interval of the nutritional component.
④Four nutritional components N-3 polyunsaturated fats (acids), α-linolenic acid, EPA, and DHA were supplemented in Table 1 "Name and order, expression units, rounding interval and '0' threshold values of energy and nutritional components".
⑤ Modified the "0" threshold value requirements of vitamin A, vitamin E, vitamin B12, niacin (niacinamide) and zinc.
⑥The allowable deviations of vitamin A and vitamin D were adjusted to be the same as those of other vitamins, and the upper limit requirement was no longer set.
9. Revised the scope of exemption from mandatory nutrition labeling
Compared with the current standard, the expressions were revised such as "fresh food, e.g. livestock and poultry, aquatic products, fruits and vegetables, and eggs", "foods whose largest surface area of packages or containers of prepackaged foods ≤ 40 cm2", and "prepackaged foods or single-ingredient condiments with daily intake ≤10 g (mL)" in the exemption labeling. In addition, the "single-ingredient dry products that have undergone simple physical treatment and no other ingredients are added, such as grains, dried fruits and vegetables" are supplemented, and "foods prepared and sold on the spot" was deleted.
10. Revised Appendix A "Nutrient Reference Values (NRV)"
Deleted the cholesterol NRV value in Appendix A "Nutrient Reference Values", the NRV value of folic acid can be expressed as 400μgDFE or 400μg, and revised the NRV values of vitamin D, biotin, choline, zinc, iodine, selenium, and copper. At the same time, supplemented a note about sodium that "2000mg sodium is equivalent to 5g salt".
11. Increased and revised the recommended formats of nutrition labeling from 6 kinds to 8 kinds
Specific text descriptions were made for each format by adding clauses, which is convenient for enterprises to understand and apply, and it was clearly stated that the format can be changed appropriately on the basis of not misleading consumers.
12. Supplemented the contents of energy and nutrient content claims and comparative claims in Appendix C
Taking the description of no energy as an example, "no calorie" was supplemented. The conditions of comparative claims were revised, requiring the measured data of the same type or category of food from the same enterprise to be derived from the data of the same type of food in the "Chinese Food Component Table".
13. Adjusted the standard dictions for function claims of multiple nutritional components in Appendix D
The dictions of function claims for α-linolenic acid, sugar, vitamin K, biotin, choline, phosphorus, potassium, and selenium were newly supplemented; deleted the function claims of cholesterol. According to the instructions of the Healthy China Concept, the warning words that long-term intake of high fat, high sugar and high salt may affect health were supplemented in the standard dictions of function claims; and the expression that "vitamin C helps maintain the normal physiological function of immune system" was supplemented.
The Draft clarified the related requirements for nutrition labeling, and promoted the healthy lifestyles of "three reductions and three health" through adjustments to the labeling of nutritional components and assisted in the implementation of the Healthy China Action (2019-2030). Compared with the previous version of the Draft, the Draft adjusted contents based on industry feedback. At present, the standard is still in the stage of soliciting opinions, and enterprises can provide timely feedback based on actual conditions.
Source: Antion
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