JOINT FAO/WHO FOOD STANDARDS PROGRAMME
CODEX ALIMENTARIUS COMMISSION
Twenty-Third Session, FAO Headquarters, Rome, 28 June -3 July 1999
Agenda Item 10
CONSIDERATION OF PROPOSALS TO ELABORATE NEW STANDARDS AND/OR RELATED TEXTS
DISCUSSION PAPER PREPARED BY
THE INTERNATIONAL ASSOCIATION OF
CONSUMER FOOD ORGANIZATIONS (IACFO)
Quantitative Ingredient Declarations on Food Labeling
QUANTITATIVE INGREDIENT DECLARATIONS
The International Association of Consumer Food Organizations (IACFO) recommends that the Codex Alimentarius Commission direct the Codex Committee on Food Labelling (CCFL) to undertake new work to revise the Codex Standard on quantitative ingredient declaration (QUID) labelling. QUID labelling is necessary to improve the accuracy and completeness of label information about the composition of foods. QUID labelling assists consumers in assessing the healthfulness and quality of foods, and helps prevent consumer deception about food composition. We have attached a proposed amendment to section 5.1 of the Codex General Standard for the Labelling of Prepackaged Foods1 to facilitate the work of the CCFL.
2. THE PROBLEM
Most, if not all, member countries require packaged multi-ingredient foods to be labelled with an ingredient list. Typically, ingredients must be listed in descending order of proportion by weight in the food. However, this requirement does not provide consumers with full information.
QUID is necessary for consumers to compare the relative amounts of ingredients between seemingly similar products. For example, two different brands of spaghetti sauce may both list the first two ingredients as water and tomatoes. Yet one brand may contain 50% water and 40% tomatoes, while the other brand may contain 70% water and 20% tomatoes. Since this difference is not detectable from the ingredient list alone, QUID is necessary to clearly indicate the proportion of ingredients in the products, allowing consumers to select the food with the greater amount of desirable ingredients.
Furthermore, QUID is essential to rectify misleading claims on food labels. Many labels imply, through words or pictures, that the food contains significant amounts of meat, fruits, vegetables, or whole grains yet those ingredients may be present in only trivial amounts, if at all. For example:
QUID reduces the likelihood that consumers will be misled by better indicating the actual amounts of ingredients in those foods. Requiring food companies to disclose the relative quantity of ingredients also enhances competition, which will result in better products being made available for sale.
- In Canada, a bottle of Libbys Strawberry Real Fruit juice contains more water and sugar than fruit juice. Based on the name, consumers might logically assume that the beverage contains 100% fruit juice, when in fact only 21% of it is fruit purée.
- In the United Kingdom, the main ingredient of a product called Minced Meats is chicken. A 1997 survey revealed that 92% of shoppers were misled by the name of this product.2
- In the United States, the front label of Kelloggs Nutri-Grain Cereal Bars states that the bars are made with whole-grain oats even though the bars actually contain more enriched white flour than whole oats. Based on this claim, many consumers might assume that the bars are a high source of whole grains.
3. EXISTING NATIONAL AND INTERNATIONAL STANDARDS FOR QUID
The government of Thailand requires that the percentage of each essential ingredient contained in products sold directly to consumers be disclosed on the label.3 In 1997, the European Union (EU) issued a directive requiring QUID for many foods, effective February 14, 20004 (France has already amended its laws to comply with the Directive.). The Directive requires QUID (expressed as a percentage of the total weight of the food at the time of use5) where the ingredient or category of ingredients concerned appears in the name under which the foodstuff is sold or is usually associated with that name by the consumer.6 In Europe, soon the amount of strawberries in strawberry yogurt and the amount of vegetables in spring rolls, for example, must be disclosed. The quantity of an ingredient must also be stated where the ingredient or category of ingredients concerned is essential to characterize a foodstuff and to distinguish it from products with which it might be confused because of its name or appearance.7
US laws only require QUID labelling for a few commodities (such as fruit and vegetable juice, peanut spread, olive oil blends, and seafood cocktail).8 While the U.S. Food and Drug Administration (FDA) encourages food companies to voluntarily provide percentage ingredient labelling on all foods, few if any have done so.9 Canada does not require that percentage ingredient information be disclosed on any product labels under any circumstances. Nonetheless, food manufacturers in the U.S., Canada, Japan and other developed countries that export to Thailand and to France (and, soon, all EU countries) must comply with national QUID rules in those countries. In so doing, they confer a benefit on those consumers which they deny to consumers in other Codex-member countries and at home.10
The current Codex standard, however, is significantly weaker than the EU and Thai standards. The Codex standard only requires the declaration of the percentage of ingredients when a food label places special emphasis on the presence or low content of a valuable and/or characterizing ingredient.11 The Codex ingredient labelling standard should be revised to reflect the best aspects of the EUs QUID requirements and Thailands percentage ingredient labelling regulations. Such upward harmonization would permit countries to require food labels providing information to advance their national health and consumer protection objectives.
4. CRITERIA FOR HAVING NEW MATERS REFERRED TO CODEX COMMITTEES
(a) Criteria for the Establishment of Work Priorities and for the Establishment of Subsidiary Bodies of the Codex Alimentarius12 require that the following factors be considered:
(b) The Draft Medium Term Plan (1998-2002)
- (i) consumer protection from the point of view of health and fraudulent practises.
- IACFO submits that revision of the Codex QUID standard is necessary to enable Codex to advance consumer protection from the point of view of promoting health and preventing fraudulent practices. Consumers who are given inadequate compositional information on food labels are unable to accurately determine the preponderance of healthful or otherwise desirable ingredients in foods they wish to purchase. Without quantitative ingredient information, consumers are not properly protected.
- (ii) diversification of national legislation and apparent resultant or potential impediments to international trade.
- IACFO notes that the current Codex general standard may limit the ability of some Members countries to validly require this important information on food labels. Revising the Codex standard may serve as an incentive for upward harmonization of domestic QUID laws in Member countries.
- (iii) scope of work and establishment of priorities between various sections of the work.
- IACFO submits that revising the Codex QUID standard does not raise any complex scientific issues. Indeed, revising the general standard for QUID is consistent with the Commissions desire to devote more attention to general standards, in preference to commodity-specific standards. An improved general Codex standard for QUID may eventually replace existing commodity-specific standards and reduce the burden of developing commodity-specific standards in the future.
- (iv) work already undertaken by other international organizations in this field.
- IACFO is unaware of any work being done by other international organizations at this time.
- (v) type of subsidiary body envisaged to undertake the work.
- IACFO submits that the CCFL is the appropriate body to undertake a review of this standard.
In 1997, the Commission indicated that a Committees proposal for new business should consider the Commissions Medium-Term Plan of Work, any specific strategic project being undertaken by the Commission and the prospect of completing the work within a reasonable time.13
Revision of the Codex QUID standard is consistent with the Draft Medium Term Plan for 1998-2002. It especially helps further the Plans objectives for nutrition and consumer information. Revising the QUID standard is not inconsistent with any of the other objectives of the Draft Plan. The Codex QUID standard can be reviewed by an existing Committee (the Codex Committee on Food Labelling) without foreseeable need to refer questions to other Codex Committees or external bodies for expert advice. Existing commodity-specific Codex QUID standards may be exempted from the general requirement to the extent of any conflict. Accordingly, this work will not unduly tax the resources of the Commission beyond a nominal increment to the routine costs of translation, reproduction and distribution of documents (expenses which are normally borne by the CCFL).
IACFO Proposal to Revise the
Codex General Standard for the Labelling of Prepackaged Foods
(quantitative ingredient declaration labelling)
Section 5.1 of the Codex General Standard for the Labelling of Prepackaged Foods [Codex Stan 1-1985 (Rev. 1-1991)] shall be deleted and replaced by the following:
5.1.1 Every food sold as a mixture or combination must disclose the percent, by weight, of each ingredient (including ingredients of compound ingredients) comprising more than 5% of the food by weight.
5.1.2 The information required in section 5.1.1 shall be written on the product label as a whole number percentage in parentheses beside the respective ingredient names in the ingredient list.
5.1.3 If the quantity of any ingredient is emphasized on the label by words or pictures, or if the product bears a name or other similarity to another food with different ingredient composition, or if an ingredient or class of ingredients is normally associated with the food by consumers, the percentage, by weight, of each of the ingredient about which the claim is made shall be reported on the label either
5.1.4 Where commodity specific standards of Codex Alimentarius conflict with the requirements prescribed here, the commodity-specific requirements shall prevail to the extent of the conflict.
- a) in close proximity to the words or images giving rise to the impression of the preponderance of the ingredient(s), or
- b) beside the common name of the food
in lettering that is at least 50% as large as the common name.
1. Codex Stan 1-1985 (Rev. 1-1991).
2. Co-op, The Lie of the Label, 6 (1997).
3. Office of Agricultural Affairs of the USDA/Foreign Agricultural Service, Thailand: Food and Agricultural Import Regulations and Standards (Fairs) 9 (July 1997).
4. See: Directive 97/4/EC of the European Parliament and of the Council amending Directive 79/112/EEC on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs, Article 1 (January 27, 1997).
5. Directive 97/4/EC, at Article 7(4).
6. Id., at Article 7(2)(a).
7. Directive 97/4/EC, at Article 7(2)(c).
8. Id. at §§ 101.30, 102.23, 102.37, 102.54.
9. See 58 Fed. Reg. 2865 (1993).
10. For instance, in the U.S., major ingredients need only be listed in descending order of weight (21 C.F.R. § 101.4(a)(1) (1997)).
11. Codex Alimentarius Commission, Codex Alimentarius Vol. 1, Section 5.1 (1995). A reference in the name of a food to a particular ingredient does not in itself constitute special emphasis, nor is quantitative labelling required if a reference is made to an ingredient that is used in a small quantity or as a flavouring.
12. Paragraph 4.B, Criteria Applicable to General Subjects, Procedural Manual (10th Ed., 1997) at 74.
13. Report of the 22nd Session of the Joint FAO/WHO Codex Alimentarius Commission, Geneva, 23-28 June 1997 at 88.