Dear Mark,
Thanks!
Yes, it all comes down to how we interpret/use the terms
recommended/mandatory use J
I find these much stronger than the “can be found” in the British Guidance
document, and I am sure that the words “can be found” have been chosen very
carefully.
All the best,
Anders
From: mark roe (IFR) [mailto:[log in to unmask]]
Sent: 21 October 2015 12:17
To: [log in to unmask]; [log in to unmask]
Cc: Mike Peters (IFR)
Subject: RE: National FCDB for nutrient labelling of branded foods
Dear Anders
The UK DEFRA ‘The Food Information Regulations 2013 Guide to compliance’
document does recommend using McCance and Widdowson data for calculation
when calculating from generally established and accepted data. I think we
have interpreted Esther’s question a little differently but it is worth
being aware of this either way since I don’t think the EU regulation defines
generally established and accepted data. I have already sent details to
Esther and the relevant wording used in the DEFRA guidelines is:
‘119. Declared values must be average values based on the following
methodologies:
a. the manufacturer’s analysis of the food;
b. a calculation from the known or actual average values of the
ingredients used;
or
c. a calculation from generally established and accepted data
120. In the UK “generally established and accepted data” can be found in
book form in McCance & Widdowson’s The Composition of Foods or online in
McCance &
Widdowson’s The Composition of Foods integrated dataset (CoFIDS) on the
National Archives website.’
One issue is that McCance and Widdowson doesn’t actually present all the
relevant information in the correct way for use in labelling, i.e.
carbohydrates are presented as monosaccharide equivalents, specific nitrogen
conversion factors are used rather than 6.25 for all foods and energy is not
calculated including fibre! The UK presents data in this way for reasons of
continuity for dietary intake surveys but we hope to be able to publish a
dataset for labelling use at some point. These differences are generally
very minor when the EU tolerance guidelines are taken into account so using
McCance and Widdowson values as published would generally be ok even if not
strictly compliant with the regulations. Most trading standards authorities
are not even aware of the differences. Interpretation of where values come
from could be a key point because if the incorrect information is used
values will be wrong (at least to an extent) but may not be misleading. Our
UK trading standards contacts will be happy as long as a reasonable process
has been used and values are not obviously misleading.
Best Wishes
Mark
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From: Food Composition Discussion Group
[mailto:[log in to unmask]] On Behalf Of Anders Møller
Sent: 21 October 2015 10:44
To: [log in to unmask]
Subject: Re: National FCDB for nutrient labelling of branded foods
Dear Esther,
First of all, currently I do not know of any countries in Europe
recommending – even making it mandatory – to use national food composition
data in the calculation for nutrition labelling, and I would be very
surprised if there is.
The Regulation (EU) No 1169/2011 lays down the principles for labelling
including nutrition labelling of prepacked foods in Europe
(http://ec.europa.eu/food/safety/labelling_nutrition/labelling_legislation/i
ndex_en.htm).
One of the main principles in the Regulation is that the
manufacturer/producer of the prepacked foods is responsible for the
information on the label, and can be fined/taken to court, if the
information is misleading or wrong.
Chapter IV of the Regulation lists the mandatory food information
(“mandatory particulars”). Article 31 clearly states
The declared values shall, according to the individual case, be average
values based on:
(a) the manufacturer’s analysis of the food;
(b) a calculation from the known or actual average values of the ingredients
used; or
(c) a calculation from generally established and accepted data.
Indent (c) above opens for the use of (national) food composition data, i.e.
“generally established and accepted data” in the process of preparing the
nutrition label.
Our Czech colleagues have together with EuroFIR AISBL prepared a Guideline
for Food Business Operators setting out the principles in calculation
information for nutrition labelling.
But it is still the responsibility of the manufacturer/producer of the
prepacked foods that the information on the label is right!
The European Commission has published a Guidance document defining which hob
big deviations from the labelled value can accepted for the actual content.
The national food inspections check labels according to these tolerances,
also how values are calculated.
Now, back to your actual question.
Yes, national food composition data can be used (indent (c)), but I would be
very surprised, if any European country would make it mandatory to calculate
nutrition labelling from national food composition data, because it would
rule out indent (b). Furthermore, I do not know of any national food
composition table/database that has the necessary detailed information on
the many industrial ingredients and food additives used in commercial food
processing.
And the food manufacturer is still responsible for the information on the
label.
So, in my view any government recommending the specific use of national food
composition data to calculate the values for nutrition labelling would
relieve the manufacturer of (some of) his responsibility, weakening the
Regulation.
All the best,
Anders
Anders Møller
Danish Food Informatics
Borgediget 12
DK-4000 Roskilde, Denmark
From: Food Composition Discussion Group
[mailto:[log in to unmask]] On Behalf Of Esther Infanger
Sent: 21 October 2015 09:33
To: [log in to unmask]
Subject: National FCDB for nutrient labelling of branded foods
Dear European colleagues,
In Switzerland we currently have a consultation process for a new
legislation which plans to make nutrient labelling mandatory like in the EU.
I’d like to know if there is a European country where it is recommended or
even mandatory by legislation to use the own National FCDB when calculating
food labels according to EU1169/2011?
If yes, I’d appreciate to get the reference of this legislation or official
recommendation.
Thank you and best wishes,
Esther
Esther Infanger, RD, MNutr
Project Manager
Swiss Society for Nutrition SSN
Schwarztorstrasse 87 | Postfach 8333 | CH-3001 Bern
T +41 31 385 00 15 | F +41 31 385 00 05 | E [log in to unmask]
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