How to read a label

If a food product is labelled then the legislation must be followed. As well as the information
required by law, manufacturers also use labels to convey their own messages, many adopt
standards such as ‘5-a-day’ by developing their own classification systems. The food industry
has a key role in helping to educate consumers about food composition, and nutrition labelling
and health claims are two ways that this is communicated. The food industry can provide
consumers with clear, consistent messages, which are based on robust scientific evidence, to
help consumers make informed decisions about the food they eat. The majority of the
information on packaging serves to inform and protect consumers.

Then there are specialised foods products, such as formula milk and weaning foods, which are
covered by further and deeper regulations. This leads to labels crammed with information on
every available space, resulting in parents often turning to their Healthcare Professional for advice, and even more so if they have concerns about allergies or conditions requiring care over
diet.

This article aims to outline what is on an infant formula label; what is required by law, why it is
on the label and what it is telling us. We also aim to explain some of the other things companies put on their labels to give you a greater understanding of the labelling environment to help make these sorts of discussions with parents easier.

What is on a label?
As mentioned, the laws and issues around food labelling are complex. There are a number or
laws and regulations in place that food manufacturers must follow:

The Trade Descriptions Act 1968 makes it an offence to apply a false trade description to any
goods or to offer to supply goods to which a false description is applied.

The Food Safety Act 1990 makes it an offence to sell food for human consumption which:

• is injurious to health
• fails to comply with food safety requirements
• is falsely described, labelled or advertised for sale
• is not of the nature, substance or quality as demanded by the final consumer.

Under the Food Safety Act 1990 specific regulations are enforced such as:

• The Food Labelling Regulations, 1996 (as amended)
• The Food Labelling (Amendment) Regulations 1998 and 1999

These regulations aim to ensure that foods are labelled accurately to inform and protect the
consumer; to enable the consumer to make an informed choice about the product from a
nutritional perspective and also to provide information on quality, safety and use of the product.
The basic information required by law to appear on labels of most pre-packed foods includes
the following:-

1. Name of the food
The name should be sufficiently precise to inform the purchaser of the true nature of the food. It
may be necessary to add a qualifying statement to clarify the name, e.g. "Vegetable Samosa - a
spicy vegetable filled pastry parcel."

If there is a name prescribed by law this must be used, e.g. "prawns". Reserved names may
only be used for foods meeting specific compositional criteria, e.g. coffee, chocolate, and jam.
Customary names that have become accepted in the UK without further explanation may also
be used, e.g. "Cream Crackers" or "Muesli".

2. List of Ingredients
All the ingredients of the food, headed by the word "Ingredients" (or a phrase including that
word), must be listed in descending order of weight.

Certain categories of ingredients, such as additives must be identified by category name, e.g.
"Preservative", and then identified by a specific (chemical) name or serial number, e.g. "sodium
nitrate" or "E250".

3. Food Allergies
There must be information provided regarding any potential allergens.

4. Claims - Nutritional Information
Some claims are prohibited; such as claims that food can prevent, treat or cure diseases or
other "adverse conditions", i.e. medicinal claims A nutrition claim is any representation that
states or implies that a food contains, or has a high or low amount of, one or more nutrients.
Nutritional claims about food which use terms such as "reduced" or "low", in relation to; energy,
protein, vitamins and mineral content in food, and for cholesterol free foods can only be made if
the food meets set compositional standards. Manufacturers must comply with these provisions
and such claims also require the provision of nutritional information. All nutritional information
must be given in the form specified in the regulations.

5. Date Marking
There are two types:

1. Use by, followed by Day and Month or Day, Month, Year. This is for perishable foods
   that usually need to be kept cold to maintain safety - example: meat, fish, dairy
   products, ready to eat salads.


2. Best Before - date until which the food will maintain its optimum quality, e.g. foods that
   become stale or develop off-flavours, such as biscuits, crisps, or soft drinks.

6. Storage Conditions
Any special storage conditions must be described, e.g. storage temperature for perishable
foods.

7. Business name and address
The label must show the name and address of:

• the manufacturer or packer, (this can be anywhere in the world;) and/or,
• a seller established within the European Union.

8. Place of Origin
The place of origin of the food is required if, by not giving it, the purchaser could be misled,
example "English Brie Cheese".

9. Instructions for Use
Instructions for use are required if it would be difficult to use the food without them, e.g.
"Preparation of infant formula".



Fig.1. Visual of preparation instructions

10. Presenting Labelling Information
Labelling information must be clearly legible, indelible, conspicuous and easy to understand. In
addition to English, other languages may be included on the label.

11. Lot Mark
You must be able to identify batches of the product by a lot mark. This is a unique code that must be prefixed by the letter "L" if it cannot easily be differentiated from other codes. The date
marking can double-up as the lot mark, provided it is in the form "day, month".

12. Field of Vision
The following must be in the same field of vision*:

• the name of the food;
• the date mark
• weight or quantity (if required);
• alcohol strength by volume (if required).

* Field of vision means; When looking at the product from a particular angle, all of this
information is visible


Fig2. EaZy pack with all fields of vision

It is against the law to pack or sell food which does not comply with food labelling legislation and so all food businesses must comply with food law outlined above. Other composition and
labelling laws apply to specific foods and to foods containing colours, sweeteners and other
additives. As you can see this is a long list of compulsory information and can be a challenge for food manufacturers, especially if the packaging is quite small; such as a jar of baby food or
formula milk tetra pack.


Fig 3. Visual of Cow & Gate Tetrapack


Infants and Young children
Then you have foods produced for infants and young children which have even further
regulations and laws to comply with.

A food for a Particular Nutritional Use (PARNUT) is one which, owing to its special composition
or process of manufacture, is clearly distinguishable from food intended for normal
consumption, and is sold in such a way as to indicate its suitability for its claimed particular
nutritional purpose.

A particular nutritional use means; the fulfilment of the particular nutritional requirements of
certain categories of people whose digestive processes are, or whose metabolism is, disturbed, or certain categories of people whose physiological condition renders them able to obtain a special benefit from the controlled consumption of any substance in food, or infants or young children in good health (FSA).

Foods for infants and young children are PARNUTS foods and are governed by EU directives
and UK legislation on composition, pesticides, health claims and advertising. The EU Directive
on Infant and Follow-on formula composition and labelling (ref) and the EU Directive on
complementary foods govern the composition and labelling of formula milks and foods for
children aged 0-3 years. The area of infant feeding encompassing; composition, pesticides,
marketing, advertising, claims and labelling, is the most heavily regulated industry, in some
ways even more so than the tobacco industry.

The formula label and legislation requirements
Infant and follow on formula legislation gives:

• minimum and maximum amounts for 50 nutrients
• − information on the levels of pesticides
• − full labelling details
• − advertising restrictions and allowances.
  
  

In relation to labelling specifically, as well as that outlined in the Food Law 1996 (above),
formula milk companies are required by the directive (ref) to put the following on a formula milk
label, with some differences for infant and follow on formulae: – in the case of infant formulae;
- a statement to the effect that the product is suitable for particular nutritional use by infants from birth when they are not breastfed
- in the case of follow-on formulae;

• a statement to the effect that the product is suitable only for particular nutritional use
  by infants over the age of six months
• that it should form only part of a diversified diet
that it is not to be used as a substitute for breastmilk during the first six months of life

• and that the decision to begin complementary feeding, including any exception to six
months of age, should be made only on the advice of independent persons having
qualifications in medicine, nutrition or pharmacy, or other professionals responsible
for maternal and child care, based on the individual infant’s specific growth and
development needs

− instructions for appropriate preparation, storage and disposal of the product and a
warning against the health hazards of inappropriate preparation and storage
− outlines which nutrients must appear in the nutrition table on a formula milk label and the
units to be used
− the necessary information about the appropriate use of the products so as not to
discourage breastfeeding
− An ‘Important Notice’ (Different for infant follow on formulae):

(a) a statement concerning the superiority of breastfeeding;
(b) a statement recommending that the product be used only on the advice of independent persons having qualifications in medicine, nutrition or pharmacy, or other professionals responsible for maternal and child care

− not include pictures of infants, or other pictures or text which may idealise the use of the
product. It may, however, have graphic representations for easy identification of the
product and for illustrating methods of preparation (only infant formula)
− be labelled in such a way that it enables consumers to make a clear distinction between
infant and follow on formula
− nutrition and health claims only in the cases listed in the Annex and in accordance with
the conditions set out within this annex (only infant formula)



Fig 4. Example of important notice on Cow & Gate pack.

This is a phenomenal amount of information required and really does present manufacturers
with major challenges of fitting all of this onto their labels, often leading to small print. All of
these details are required and added to formula milk labels to ensure that the nature and use of
the product is fully understood, to ensure and reinforce the superiority of breastfeeding and to
ensure that the product is prepared safely and correctly for use with infants.

Company specific messages
Companies follow these regulations while also striving to provide insightful and useful
information to mothers. All formula companies use their labels to highlight the special qualities
of their milks so that parents and healthcare professionals are better informed, and can
therefore make an informed decision on what to feed the infant in their care.

Examples include; feeding guides, journey tools, icons and stamps of approval, tick lists and
easy to understand benefits/ingredients/composition.


Fig.5. Examples of icons & logos

Food Standards Agency
The Food Standards Agency (FSA) is responsible for making sure that the rules on the safety of
materials that come into contact with food are enforced. Food contact materials include the
containers food is sold in, the packaging, as well as the articles used to handle food, from food
processing machinery to cutlery. The FSA have produced a number of guidance documents in
relation to food labelling for use or reference by manufacturers if they wish to use it. Examples
include; allergen labelling, nutritional claims in food labelling and health claims and Guidance
Notes on the Infant Formula and Follow-on Formula Regulations (2007). These guidance
documents are not law but refer to UK and EU legislation.

New Nutrition and Health Claims legislation
Recently new nutrition and health claims legislation was issued for the EU. Article 13 of this
Regulation on nutrition and health claims made on foods required EU Member States’
competent authorities (in the UK the FSA) to submit a list of draft health claims to the EU
Commission. This draft list includes claims (submitted to the Agency by industry) that were
eligible for consideration to be on the EU list of permitted claims. The European Food Safety
Authority (EFSA) is currently assessing submissions from all Member States and the EU will
produce a list of permitted health claims in the near future.

Claims eligible for consideration are these only:

− those describing or referring to the role of a nutrient or other substance in growth,
development and the functions of the body
− psychological and behavioural functions
− slimming, weight control, a reduction in the sense of hunger, an increase in the sense of
satiety and the reduction of the available energy from the diet

To qualify for the EU list, the claims must be based on generally accepted scientific evidence
and be well understood by the consumer. The claims were submitted to ESFA at the end of
2007 under the following groupings:

1 – Carbohydrates, Diets, Fats, Fibre, and Foods and Beverages
2 – Minerals and other
3 – Probiotic Ingredients, Protein, and Vitamins
4 – Plant substances with no known medicinal use in the UK
5 – Plant substances with medicinal use in the UK

Reduction of disease risk claims
Article 14 states claims referring to the development and health of children have to be registered through individual dossiers. Until adoption of the new EU list, companies must continue to comply with current legislation.

Why so heavily regulated?
As noted earlier the infant feeding industry is the most heavily regulated of all food industries.
This is due to a number of reasons:

– Infants are the most vulnerable group within the population.
– We want to provide them with the best start in life and nutritionally that is breastfeeding. Much of the legislation aims to protect breastfeeding and to ensure that it is understood to
be the best nutrition for infants.
– Safety. As this group is vulnerable and more susceptible to physiological upsets including
infection, allergy and digestive problems, safe preparation is of utmost importance.
– Information on labels also serves to reassure the parent and healthcare professional that
the product has been manufactured safely and in line with legislation.
– Information. The labels provide a wealth of information; nutritional composition and
ingredients, use by dates and key message to better inform the public about the product.

All of this serves to inform and protect the consumer.

Conclusion
Food labelling is complex and subject to change and the area of infant feeding is even more
complex. As well as the labelling legislation set out in the Food Labelling Act 1996, infant
formula manufacturers must comply with specific UK and EU directives in relation to
composition, labelling, health claims and advertising. Changes made to legislation by the UK
and EU authorities require industry to adapt the labels and messaging providing ever changing
challenges.

Given the amount of information that is required by law on a label, as well as company specific
messaging, parents often turn to their Healthcare Professional for advice. The label can be
broken down into a few discreet areas which can make it easier to understand:

– Front of pack- name, use, age range
– Nutrition information, ingredients, shelf life
– Preparation guidelines
– Feeding guidelines
– Company messages

References
The UK Trade Descriptions Act 1968 (c.29)
The UK Food Safety Act 1990 (c.16)
The UK Food Labelling Regulations, 1996. Statutory Instrument 1996 No. 1499
The Food Labelling (Amendment) Regulations 1998. Statutory Instrument 1998 No. 1398
The Food Labelling (Amendment) Regulations 1999. Statutory Instrument 1999 No. 747
European Commission Directive 2006/141/EC on infant formulae and follow-on formulae
The Infant Formula and Follow-on Formula (England) Regulations 2007. Statutory Instrument 2007 No. 3521
The Nutrition and Health Claims (England) Regulations 2007. Statutory Instrument 2007 No. 2080
European Food Safety Authority. http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_home.htm, accessed October 2008

Other links
FSA - http://www.food.gov.uk
EU Infant formula and follow on formula Directives -
http://ec.europa.eu/food/food/labellingnutrition/children/formulae_en.htm
Codex Alimentarius - http://www.codexalimentarius.net/web/index_en.jsp