How to Make Compliant Nutrition Information for Prepackaged Common Food?

Nutrition Information is an important part of prepackaged food label. How to indicate the Nutrition Information? What contents are mandatory? CIRS will interpret the requirements for nutrition information of prepackaged common food around GB 28050-2011 (General Rules for Nutrition Labeling of Prepackaged Foods) as following:

1. The scope of application of GB 28050

Prepackaged common foods, excluding health foods and special dietary foods.

2. Basic elements

It includes 5 basic elements: table title, nutrient name, content, NRV% and table line.

CIRS Tips:

1) The table title should be "營養成分表", rather than "營養成份表";

2) The content should be the exact values. The range values, the lowest values or the highest values cannot be used.

3. Mandatory labeling content

1) The content of energy and four core nutrients (protein, fat, carbohydrate, sodium) (hereinafter referred to as "4+1") and their percentage of nutrient reference value NRV (NRV%). Example:

Nutrition Information

2) When making nutrition claims or nutrient function claims for nutrients other than "4+1", the content of the nutrients and their NRV% should be indicated.

3) When using nutrient enhancers, the content of the nutrient enhancers used and their NRV% should be indicated;

4) Products using hydrogenated and/or partially hydrogenated fats and oils should be labeled with the content of trans fat (acid) in the Nutrition Information.

CIRS Tips:

1) When other nutrients are indicated in the Nutrition Information, "4+1" should be marked conspicuously (by the way of changing the font, increasing the font size and so on);

2) Nutrients without NRV value do not need to be indicated with NRV%, which can be expressed by blank, diagonal or horizontal lines;

3) Non-nutrients should not be indicated in the Nutrition Information, such as probiotics.

4. The expression of nutrients

The name and sequence of nutrients, the unit, rounding interval, and the threshold of "0" shall comply with Table 1 of GB 28050. The requirements for "4+1" are as below:

CIRS Tips:

1) The unit of energy is "kJ" and should not be indicated as "kj" or "Kj";

2) When the content of a nutrient is ≤ "0" threshold per 100g or per 100mL, its content should be indicated as "0". For example, threshold of "0" for energy is 17kJ/100g, when the energy value is 16kJ/100g, it should be labeled as "0kJ" in the Nutrition Information.

5. Methods for obtaining nutrient content

a) Direct test: select the test methods specified by the national standards. In the absence of the national standard methods, the methods recommended by AOAC or other recognized methods can be selected to obtain the value of nutrient content through testing the product.

CIRS Tips:

1) In principle, the more samples and test times, the closer the data is to the true value. In practice, enterprises should select multiple batches and quantities of samples for testing to ensure the reliability of the labeled data;

2) The energy indicated in the Nutrition Information is mainly obtained by calculation. Take "4+1" as an example: energy = 17kJ / g * protein + 37kJ / g * fat + 17kJ / g * carbohydrate. Companies are advised to use the revised values in the Nutrition Information for calculations.

b) Indirect calculation: it can be calculated according to the product formula by using the nutrient content data of raw materials or the reliable food ingredient database data.

CIRS Tips:

There will be individual differences in the nutrient content of the same kind of food ingredients, and the product processing may also affect the nutrient content of the ingredients. Therefore, there may be large errors in the values obtained through indirect calculation, especially when the product formula is complex. Therefore, it is advised for enterprises to directly test the nutrition content.

6. Calculation of NRV%

NRV%=X/NRV×100%

X—the content of a nutrient; NRV—the corresponding nutrient reference value

Example: the NRV of energy is 8400kJ, if the energy of the product is 500kJ/100g, its NRV%=500/8400×100%≈6%.

CIRS Tips:

The rounding interval of NRV% is 1, such as 1%, 2%, rather than 1.5%, 2.5%.

7. Nutrition Information compliance test

1) During the shelf life, the allowable error range of energy and nutrients should meet the corresponding requirements. Take “4+1” as examples:

2) If there are requirements for nutrient content in the corresponding product standards, the requirements in the product standards and the allowable error range of Nutrition Information shall be met at the same time.

Example: Whey powder and whey protein powder (GB 11674-2010) stipulates that the protein content in whey protein powder should be ≥ 25.0g/100g. If the protein in the Nutrition Information is 30.0g/100g, although the allowable error range is ≥ 24.0g/100g, the actual content of the protein should be ≥ 25.0g/100g.

8. Prepackaged food exempt from the Nutrition Information

1) Fresh food, such as packaged raw meat, dried mushroom without other ingredients;

2) Alcoholic beverages with alcohol content ≥0.5%, such as fermented alcoholic drink;

3) Food with total surface area of package ≤100cm2 or maximum surface area ≤20cm2;

4) Food prepared and sold on the spot, such as milk tea;

5) Packaged drinking water;

6) Prepackaged food with daily consumption ≤10g or 10mL, such as monosodium glutamate and tea;

7) Prepackaged food that is not required to indicate the Nutrition Information according to other laws and regulations.

CIRS Tips: When the conditions for exemption are met, the Nutrition Information shall be indicated in accordance with the requirements of GB 28050 if:

1) The company voluntarily indicates the Nutrition Information;

2) Information on nutrients, nutrition claims or nutrient functional claims are indicated on the product label;

3) Nutrition enhancers are used;

4) Hydrogenated and/or partially hydrogenated vegetable oils are used.

Conclusion - Key Points of Nutrition Information Review:

1) Whether the product is exempt from the Nutrition Information;

2) Whether the table title is missing;

3) Whether the name, the order, the unit, the rounding interval are correct, and whether the values are ≤ threshold of "0";

4) Whether the calculation of energy and NRV% are correct;

5) Whether the product has nutrition claims or uses nutrition enhancers, and whether the corresponding nutrients are indicated in the Nutrition Information;

6) Whether the labeling of trans fatty acids is required;

7) When indicating other nutrients, whether "4+1" are marked conspicuously

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