About Food Labelling
Food Labelling and Advertising Regulations
Compiled by Gabi Steenkamp, Registered Dietician, South Africa
With the new South African food labelling and advertising regulations (R146) having been passed in March 2010, all labels and advertising of food products in South Africa must be compliant.
Why is there legislation on Food Labelling?
In the past, South African food manufacturers have used marketing strategies that mislead the consumer, not only directly with blatant untruths printed on labels, but also by misleading the consumer with half truths or by implication on labels and marketing information.
A good example of this are the vegetable oils that are labeled ‘contains 0 % cholesterol’, when in fact all vegetable oils DO NOT contain cholesterol. By implication, consumers would then assume that only those oils labeled with the ‘contains 0 % cholesterol’ are the healthier choice as only they contain no cholesterol.
The facts however are:
- All vegetables oils are naturally free of cholesterol
- Vegetable oils have differing fatty acid compositions which function differently in the body – this is the pertinent information the consumer should be given
- All vegetable oils have the same energy value ( kJ or Cal), and there is no such thing as a ‘lite’ vegetable oil
- Vegetable oils are manufactured by different methods, and this may affect the nutritional content of the oil. Again, information the consumer should be made aware of.
To address these problems, the Food Directorate of the Department of Health, has been hard at work reformulating the Food Labelling Regulations.
In essence, the objective is to create an equal platform for all products by stating:
- only facts
- not confusing the consumer by word or implication
- using the label as a platform for consumer education
Technical Explanation on our Consultations
Our advice is based on the regulations of March 2010 (R146) as well as the published R429 draft of the regulations as a guideline for those issues are not covered by R146. Some of the finer detail of the regulations will probably still change in the final of the R429 regulations when they are passed, but we try to ensure that this will be kept to a minimum when compiling the report on your product label evaluation.
Some mandatory information required on Food Labels in South Africa
- An accurate name of the product informing the consumer of exactly what is in the packaging.
- The ingredients listed in descending order of mass
- All allergens must be identified in the prescribed format
- The country of origin
- A batch identification number
- A use by date / Best before date
- The Typical Nutritional Information Table for ALL products, in the prescribed format. Products without claims may use calculated nutritional analysis values. This is going to be the case once the new R429 is passed, so it would be prudent to get this done on all new food labels.
- Name and address in South Africa of the manufacturer or importer or distributor
- Net contents in metric units
- Agricultural products must also comply with the relevant agricultural standards act for that specific food.
Words make a Food label
The following words may not appear on any food product:
- x % fat free. One must state ‘contains xx % fat’.
- Nutritious or other words implying the same thing. This would include the word ‘goodness’.
- Healthy / healthful / health or other words implying the same thing.
- Wholesome / complete nutrition / balanced nutrition and other words implying the same thing.
- “Sugar free” and “Fat free” are only allowed, if specific conditions, as set out in the Food Labelling Regulations are met.
- “Suitable for those with diabetes”, “diabetic friendly” or words with a similar meaning, may technically not be used.
All descriptive words must be carefully chosen to ensure that no implied claims are inadvertently made and that descriptions such as “home made” or “natural” etc. fall within the CODEX definitions.
- R146 only makes provision for limited specific claims with specific wording that must be included on the label and/or advertising of the product.
- If any claim is made, certain provisos must be met, the least of which is that the nutritional analysis of the product must be done by a reputable SANAS accredited laboratory, following accredited procedures as set out in the regulations. No calculated nutritional information is allowed in this case.
- R429 will contain more nutritional claims. For example glycemic index claims (absorption rate of a carbohydrate containing food), must be properly tested as set out in the regulations by a SANAS accredited organization.
- The endorsement programme of DIABETES SA is run by the Glycemic Index Foundation of SA (GIFSA), which is run by qualified dietitians. This endorsement has been approved by the Department of Health until R429 has been passed.
- Endorsement of a product may only be granted by an organization where the endorsement programme is run by professionals, and where the specifications have been set up in keeping with the latest research.
- No company may endorse its own products.
- No health professional may endorse food products.
See the government website for more detailed information.
For a food labelling consultant, or food labelling workshops please contact Gabi Steenkamp