Nutrition Meets Food Science

Are labelling compliance requirements clear to businesses

Nutrition labelling first introduced in 2008 (PFA), only required declaring the “big four” nutrient amounts; energy (kcal), protein, carbohydrate (including quantity of sugar) and fat. Expressing the amount of nutrients in a product as percent of daily requirements for healthy diets, was introduced by LD 2020. The amounts of the following six nutrient amounts in a product must be given as a percentage of total fat (67g), saturated fat (22g), trans fat (2g), sugar (50g) and salt (5g). These reference amounts are themselves based on percentages of 2000 kcal daily energy of the diet. They are only reference values for labelling food products and not individual dietary recommendations.

In labelling two reference amounts are use; one for declaring amount of micronutrients and another for macronutrients associated with non-communicable disease (NCD). Both use the term RDA.

The term Recommended dietary allowance (RDA) was designed to prevent nutrient deficiency diseases in a given population, and the original approach did not include nutrition labelling. The ICMR RDA publication was not prepared for a regulatory purpose but was intended for public health use like nutrition surveys, clinical recommendations, data for government feeding programs etc. Regulation was never the intention, and therefore they do not have single cut offs.

Codex uses the term Nutrient Reference Value (NRV) which was specially coined to avoid confusion with the US term RDA. The US uses the term Daily Values (DV) and EU Reference Intake (RI) for labelling purpose, not RDA. Furthermore these terms comprise a single set of values for all individuals in a population not multiple sets of values for sub-groups within the same population. Codex, US and EU provide a single set of values for all individuals of the population above a certain age e.g., 36 or 48 months. The FSS LD 2020 regulations instead of notifying a single set of values similar to Codex NRVs (CXG 2-1985) and other countries, it published ICMR’s multiple sets of recommendations for sub-groups prompting queries from businesses: “Which RDA value is to be declared on the product label”.

Using the term RDA in nutrition labelling is inappropriate. Besides using the term RDA for both micronutrients and macronutrients is improper as their methods of derivation is different. RDA is derived from Estimated Average Intake (EAR) while macronutrient amounts are derived from 2000kcal energy. However to avoid consumer confusion, a single term is to be used, but not RDA. Finally, label declarations is to inform consumers on nutrient amounts contained in the product; it is meant to be informative not prescriptive.

Dr. Joseph Lewis

Chairman- Regulatory Affairs Committee, PFNDAI

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