Journal of Human'Nu t rit ion June 1980

Nutritional labelling For reasons I have never quite fathomed nutritional labelling is, as I have commented elsewhere (Allen, 19 75), a subject that arouses surprisingly strong feelings. At one extreme are those who oppose the display of information about energy and nutrient content on labels of foods intended for general consumption as unnecessary, potentially confusing, and calculated to mislead the lay con- sumer. A directly opposite view is that consumers have a natural right to detailed information about the nutritional value of all foods at the time that they buy them and that manufacturers of processed foods should be obliged to provide it.

The truth must surely lie somewhere between these extremes. I personally see nutritional labelling as a logical extension of ingredient labelling which may at present interest only a minority of consumers, but a minority that will grow with the spread of nutrition education. Indeed, nutritional labelling may itself encourage an interest among consumers in nutrition and its application, through dietetics, to food and health.

In any case, whether one approves or not, there is already nutritional labelling in a number of countries and the signs are that it will become increasingly common. In the United Kingdom an element of nutritional labelling is required in support of claims and there are in addition some voluntary declarations (Allen, 1977). Nutritional labelling is at its most highly developed in the United States where regulations (Food & Drug Administration, 1978) prescribe in detail the information to be given and the form in which it is presented. Nutritional labelling is mandatory only where nutritional claims are made or nutritional information is given on labels or in advertisements or nutrients are added t o a food. In the Federal Republic of Germany nutritional labelling is required for foods intended for particular nutritional purposes or when certain claims are made for foods in general consumption. In Denmark there are guidelines (Statens Levnedsmiddeiinstitut, 1975) which leave manufacturers considerable latitude as to content and form. Work to establish a framework for nutritional labelling in the Netherlands is well advanced (Editorial, 1980). Progress has been made in formulating a common policy on nutritional labelling within the food processing industries of the European Economic Community (Allen, 1980). Interest at the international level is reflected in the work of the Codex Committee on Food Labelling, which has made tentative proposals for an international standard (Codex Alimentarius Commission, 19 79). These proposals, however, have a long way to go through the Codex procedure before they are ready for consideration by governments for possible acceptance.

Of more immediate importance for the United Kingdom are the comprehen- sive recommendations regarding nutritional labelling contained in a recent report by the Food Standards Committee (1980). Starting from the premise that it would be wrong to prevent manufacturers from giving nutritional information on labels provided this information is accurate and not misleading, the Com- mittee makes proposals for guidelines which they consider necessary to ensure

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that any wider introduction of nutritional labelling will take place in an orderly and generally acceptable manner. The relevant paragraphs in the report deserve careful study but the essential features of the Committee’s conclusions and recommendations might be summarised in the following terms. 1. Legislation t o require nutritional labelling of a wide range of foods would not

benefit consumers at present. Nutritional labelling should be mandatory only when (1) Claims are made relating to energy, protein, vitamins or minerals or fo r

suitability for slimming or diabetic use or when (in accordance with other recommendations in the report) statements are made in prescribed form about the proportions of fat, polyunsaturated and saturated fatty acids or of cholesterol in the food or,

(2) Food constituents considered to be nutritionally important are listed on the label, for example fibre, salt, sucrose or sorbitol.

Reference to any of these entities in a list of ingredients would not, however, require nutritional labelling.

comply with the provisions that follow.

present, even if minimal or zero, of energy, protein, fat, carbohydrate and the ‘scheduled’ vitamins and minerals. These are the vitamins and minerals for which the Committee recommends that claims should be permitted, namely vitamin A, thiamin, riboflavin, niacin, folk acid, vitamin B, * , vitamin C, vitamin D, calcium, iodine and iron. The Committee considers that the requirement always to make a full statement of this kind will reduce the danger of over-emphasis on a particular nutrient that could arise from selective declarations.

4. Energy and nutrients should be declared as the minimum amounts present in a serving of specified size (but energy per unit weight when slimming claims are made). The number of servings per pack should also be stated. The Committee favours declarations per serving as more informative to the consumer than per 100 g or 100 ml, which could mislead when applied to food normally eaten only in small amounts. Amounts per unit weight or volume or per pack can easily be calculated when necessary.

appropriate. Vitamins and minerals should be declared as a percentage of’ the recommended daily amounts (Department of Health & Social Security, 1979) : when this is less than 5 per cent a disclaimer t o this effect should be required. This form of declaration is considered by the Committee to be more readily understandable by consumers than declarations in absolute amounts.

should be set out on the label in standard sequence within a ‘box’. Thcrc should be a footnote clarifying the significance of ‘recommended daily amounts’ of nutrients.

7. Details of food constituents considered to be nutritionally important (scc paragraph 1[2]) as well as decIarations of fatty acid or cholesteroI kvck , should be contained in the same box but below a line drawn under the

2. All nutritional labelling, whether mandatory or carried out voluntarily, should

3. Without exception, information should always be given about the amounts

5. Energy, protein, fat and carbohydrate should be declared by kJ or weight as

6. For ease o f reference all the information specified in paragraphs 2-5

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footnote. Here too should be located statements relating to ‘non-scheduled’ vitamins and minerals for which only very restricted claims would be allowed, namely vitamin B6 , pantothenic acid, biotin, vitamin E, phosphorus, potas- sium, fluorine, zinc, copper, chromium and manganese.

8. All nutritional information on the label should relate to the food as sold. This follows from the Committee’s endorsement of the view expressed in a previous report (Food Standards Committee, 1966) that ‘no claim should be made for particular value in a food when that value is not wholly contributed by the food, but is partly contributed by other food with which it may be consumed (eg the caloric value of a breakfast cereaI on the basis that it will be eaten with milk and sugar)’. It is also consistent with the principle that the manufacturer’s responsibility for his product relates t o the food at the time of sale. The Committee considers that the uniformity that these recommendations

aim to achieve is necessary for clarity and ease of understanding of the informa- tion provided. It also suggests that implementation by incorporation in a code of practice negotiated between food manufacturers and the enforcement authori- ties would be adequate for most of the recommendations rather than by means of strictly drawn regulations. The Committee leaves open for further discussion the much larger question of possibly requiring declarations of energy, fat and perhaps protein on all foods, whether fresh or processed.

to what extent they are eventually reflected in legislation will be decided by Ministers after taking Account of representations received by 10 September next (Ministry of Agriculture, Fisheries & Food, 1980).

Although the British Dietetic Association was not among the 35 organisations and individuals who submitted evidence to the Committee specifically on nutri- tional labelling, I believe that dietitians are in a special position to contribute to the debate on this report and that it is therefore important that they should make their collective voice heard by submitting reasoned comments to the Ministry of Agriculture, Fisheries & Food. I shall be surprised if dietitians do not also have something to say about other recommendations in the Committee’s report regarding claims and misleading descriptions. No other group is better qualified by direct experience in the application of nutritional principles and through their involvement in nutrition education to comment on the Commit- tee’s proposals and thus to contribute to the establishment of a system of‘ nutritional labelling which will be as useful as possible for the consumer. There will not be another opportunity for many years for the profession to influence legislation in a field that is peculiarly relevant t o their interests.

The Committee’s recommendations are in no way binding. Whether and if so

R. J . L. A llen, OBE, MSc, PhD Lately Visiting Professor o f Applied Nutrition, Guy’s Hospital Medical School, London, S E l ; 63 Ahbotshury Close, London W 1 4 8 E Q England.

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References Allen, R.J.L. (1975): Nutrition labelling. Brit. Nutr. Fndn Bull. 3, 113. Allen, R.J.L. (1977): Food standards and nutrition. Proc. Nutr. SOC. 36, 91. Allen, R.J.L. (1980): Nutrition and the food and drink industries. Fd Drink Znd. Council Bull.

Codex Alimentarius Commission (1979) : Report o f t h e thirteenth session o f t h e Codex

Department of Health & Social Security (1979): Recommended daily amounts of f ood energy

(in the press).

Commit tee on Food Labelling. Rome: FAO/WHO.

and nutrients for groups of people in the United Kingdom. Report on health & social subjects 15. London: HMSO.

Federal Republic of Germany.) Commission of the European Communities Symposium on Nutrition, Food Technology and Nutritional Information, London, March 19-2 I .

Editorial (1980): Prof. Krol over de voedingswaardewijzer : een concrete doelgerichte aftrap. Vai-Nieuws 6, No. 5 , 2 - 8.

Food and Drug Administration (1978): Code of Federal Regulations. Title 21 - Food and Drugs, Section 101.9 : Nutrition labelling of food, pp. 17-22. Washington DC: Office of the Federal Register.

HMSO.

London: HMSO.

Eckert, D. (1980): Declaration of nutritive value pursuant t o legislation (as exemplified b y the

Food Standards Committee (1966): Report o n claims and misleading descriptions. London:

Food Standards Committee (1980): Second report on claims and misleading descriptions.

Ministry of Agriculture, Fisheries & Food (1980): Press Notice, March 10. Statens Levnedsmiddelinstitut (1 975): Vejledning vedrbrende nmringsdeklarationer. SBborg:

Statens Levnedsmiddelinstitut.

The address of the British Dietetic Association is: Daimler House, Paradise Street, Birmingham, B 1 2BJ (Telephone: 021-643 5483).

The intention of Journal of Human Nutrition is to provide a forum for all those concerned with the science of human nutrition and with the application of that science to the feeding of people in health and disease. The aim is to bring together in ohe place papers from many relevant disciplines. The scope of the journal encompasses not only the biochemistry and physiology of nutrition and the study of diet and disease, but also reaches o u t into the fields of food science and technology; into nutritional aspects of cooking and catering; into the sociology and psychology of food; into home economics: and into the global problems o f over-population and food supplies.

contributions on all aspects of human nutrition, from nutritionists, dietitians, clinicians and members of all relevant scientific, clinical, and practical disciplines.

The journal publishes research reports (usually between 2000 ,ind 4000 words); full review articles (around 5000 words -prior consultation advisable); ‘semi-review’ articles which report and comment on interesting research or practical topics, without covering all the current knowledge in the subject, but referring with adequate balance to conflicting evidence or views; papers describing dietetic subjects and practices, and letters (up to 350 words) comprising original short statemen ts -with necessary evidence or references- on subjects of interest. Statements and claims made by advertisers and opinions expressed in the articles appearing in ‘Journal of Human Nutrition’are those of the advertisers and authors respectively and no t necessarily those o f the BDA or the publishers.

Journal of Human Nutrition welcomes the submission of original (unpublished)

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