Interpretation on 8 Highlights in the Draft of GB 28050

On August 31, 2020, the National Health Commission (NHC) issued drafts of 16 food safety national standards for public comments, and the deadline for comments is October 20, 2020.

Among the drafts, the one that received the most attention could be the draft of Food Safety National Standard General Principles for Nutrition Labeling of Prepackaged Food (GB28050, hereinafter referred as “the draft”). CIRS therefore, summarizes and interprets several key changes on the draft compared to the current GB28050, so as to help enterprises understand the future design direction of nutrition labels of prepackaged food.

1. The mandatory items of nutrition label are changed from “1+4” to “1+6”

• The draft states that, the compulsory items of prepackaged food nutrition label shall include: energy and the content of protein, fat, saturated fat (or saturated fatty acid), carbohydrate, sugar, and sodium as well as their NRV% (percentage of Nutrient Reference Values), respectively.

Interpretation: the current GB28050 stipulates that, the compulsory items are energy and the content of protein, fat, carbohydrate and sodium as well as their NRV%, respectively, while the content of saturated fat (or saturated fatty acid) and sugar as well as their NRV% are required by the draft, which makes the compulsory items change from “1+4” (energy + protein, fat, carbohydrate and sodium) to “1+6” (“1+4” plus saturated fat (or saturated fatty acid) and sugar).

2. Expressions and labelling on nutrients are recommended and supplemented

• When labeling nutrients other than the “1+6”, the “1+6” can take the form of increasing the font size, changing the font (such as italic, bold or black), and changing the color (text or background color) to make them stand out.
• Several nutrients are supplemented in Table 1 and the rounding interval and the “0” limit value of some nutrients are revised.

Interpretation:

1. The expression approaches are recommended by the official Q&A of the current GB28050, and are incorporated into the draft;
2. n-3 polyunsaturated fatty acids, α-linolenic acid, EPA and DHA are added in Table 1;
3. The rounding interval and/or the “0” limit value of vitamin A, vitamin E vitamin B12, niacin and zinc are adjusted.

3. Definition and application scope of NRV and NRV% are determined

• NRV is a reference value used to compare the nutrient content level in nutrition label of prepackaged food and applies to food consumed by the population above 4 years old.
• NRV% refers to the content of a certain nutrient in every 100g, 100ml or per serving of the edible part of a food to the NRV of this nutrient. 100% of a nutrient on NRV% means that it can meet the daily nutrient requirements of individuals above 4 years old.

Interpretation: the definition and application scope of NRV and NRV% are poorly defined in the current GB28050 while are fairly clear in the draft. The more important is that, the applicable population of NRV are the population over 4 year-old.

4. Calculation of energy and carbohydrate are more specified

• If the content of other energy-yielding components in food exceeds 1g/100g, they should also be included in energy calculation. The energy conversion coefficients of other energy-yielding components are (kJ/g): 29 for ethanol, 13 for organic acid, and 10 for sugar alcohols (including D-mannitol, maltitol, lactose alcohol, sorbitol, and xylitol).
• The amount of carbohydrate in food can be calculated by subtraction or addition. When food ingredients contain ethanol, organic acids, sugar alcohols and other energy-yielding components and require energy conversion, carbohydrate calculations require an additional deduction of these components.

Interpretation: the draft refers to GB/Z 21922 to increase the definition of energy, protein, fat and fatty acid, carbohydrate and sugar, and refines the calculation of energy and carbohydrate, and adds other energy-supply substances (ethanol, organic acid and sugar alcohol) requirements in energy calculations. Compared with the current GB28050, the calculation of carbohydrate and energy is more accurate and strict.

5. Requirements on nutrition table marked with per serving are specified

• The content of energy and nutrients can also be marked with specific values as per serving, and the weight or volume of per serving should be marked on the same page. The weight and volume of per serving can refer to the reference values of various foods recommended in Appendix E of the draft.

Interpretation: “serving reference value” refers to the recommended reference weight or volume (of edible portion) of each food when the nutrition table is indicated by “serving”. This is the first time the application of the “serving reference value” has been proposed. Some values may differ greatly from the current amount defined by enterprises themselves, thus, they might be adjusted in time.

6. Scope of exemption on nutrition table are revised

• The scope of exemption on nutrition table is amended considering the uncertainty of food composition or other conditions, which are:
• Add “single raw or dried products that are simply handled or cleaned, such as rice, wheat flour, coarse grains, etc.”
• Amend the exemption conditions of alcohol: from “alcohol beverage with alcohol content ≥0.5%” to “alcohol beverage with alcohol content ≥0.5% and sugar content < 0.5%”
• Expand the upper limit of small package food: from “package area ≤100cm2 or maximum surface area ≤20cm2” to “package area ≤150cm2 or maximum surface area ≤40cm2”
• Add “foods that are packaged in reusable glass (porcelain) bottles, and labels cannot be printed on the bottle”
• Revise the exemption condition of small consumption products: from “prepackaged food with daily consumption ≤10g (ml)” to “prepackaged food with daily consumption ≤10g (ml), or single raw material condiments”

Interpretation: the conditions on nutrition table exemption are refined and expanded.

7. The scope of reference food in comparison claims is clarified

• The draft states that, reference food for comparison claims shall be:
• The measured data of the same kind or the same category of food in the same enterprise;
• The data of the same kind of food from China Food Composition Tables.

Interpretation: the current GB28050 defines reference food as: the same kind or the same category of food that are well known and easily understood by consumers, which is relatively vague, and it is clarified in the draft, which can gradually guide enterprises to standardize the use of comparison claims.

8. Functional claims of some nutrients are supplemented and revised

• The draft added functional claims for α-linolenic acid, sugar, vitamin K, biotin, choline, phosphorus, potassium and selenium, and supplemented functional claims for protein, vitamin A, vitamin B6, vitamin B12, calcium, magnesium, zinc and iodine.

Interpretation: in addition to the nutrients of which the functional claims are added and supplemented, some are removed due to a lack of sufficient evidence, such as “carbohydrate should account for about 60% of energy supply in the diet” and the functional claim for cholesterol. Overall, the release of the new GB28050 would provide more choices of functional claims and make it more scientific.

Conclusion

In addition to the major changes mentioned above, there are many adjustments and refinements of the draft compared to the current version, such as clearly stipulating the applicable and non-applicable scope of the standard, and clearly categorizing mandatory labeling items and optional labeling items, etc. At present, the standard is still in the stage of soliciting opinions, and enterprises can timely give feedback according to their own situation. CIRS does not expect much change between the formal version and the draft, and recommends enterprises preparing for the changes in advance.