CSPI International
Center for Science in the Public Interest

Diet & Health/Food Labelling & AdvertisingFunctional FoodsFood Safety StandardsIACFOCodex Alimentarius CommissionWorld Trade OrganizationNAFTAGeneration ExcessSafe Food International

Joint FAO/WHO Food Standards Programme

Codex Committee on Food Labelling
Twenty-Eighth Session, Ottawa, Canada, 9-12 May 2000

Discussion Paper on Quantitative Ingredient Declaration
(CX/FL 00/12)
Submitted by the International Association of
Consumer Food Organizations

I. Introduction:

     At the meeting of the Codex Alimentarius Commission in Rome, 28 June - 3 July 1999, the Commission noted the recommendation of the International Association of Consumer Food Organizations (IACFO) that the Committee on Food Labelling undertake to revise section 5.1 of the Codex General Standard for the Labelling of Prepackaged Foods concerning Quantitative Ingredient Declaration (QUID) labelling. The Commission agreed that the recommendation be examined by the Committee.(1)

II. The Need for QUID Labelling:

     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 about food composition, nor does it enable consumers to compare the quality of different foods.

     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 quality, and in some cases, the healthfulness of foods and helps prevent consumer deception about food composition. The following illustrations demonstrate the need for QUID labelling.

     First, QUID informs consumers if a particular ingredient is present in a significant amount. For example, the first ingredient of a product might be listed as meat. Simply listing ingredients in order of predominance does not inform consumers whether meat comprises closer to 30% of the product or 90% of the product. QUID is necessary to indicate exactly how much meat the product contains so that consumers can make more educated purchasing decisions.

     Second, 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.

     Third, QUID is essential to rectify misleading claims on food labels. Many labels imply, through words or pictures, that a 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, a bottle of "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 it contains only 21% fruit puree. Furthermore, the front label of a package of cereal bars states that the bars are made with "whole-grain oats" even though the bars actually contain more refined white flour than whole oats. Based on this claim, many consumers might assume that the bars are a high source of whole grains. QUID is necessary to indicate the relative amounts of ingredients in those foods, thereby reducing the likelihood that consumers will be misled.

     Fourth, QUID provides manufacturers with the incentive to increase the quality of food products. Requiring food companies to disclose the relative quantity of ingredients enhances competition and encourages companies to improve the composition of their foods, which will result in better products for consumers.

III. Existing National Standards for QUID

     Some countries already require QUID labelling. For more than a decade, Thailand has required that the percentage of each major ingredient contained in products sold directly to consumers be disclosed on the label.(2) Recently, the European Union (EU) began requiring QUID for many foods.(3) The EU directive requires QUID 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."(4) For example, the amount of strawberries in "strawberry yogurt" and the amount of vegetables in "spring rolls" must be disclosed.(5)
  • "the ingredient or category of ingredients concerned is emphasized on the labelling in words, pictures or graphics."(6) For example, if a food is described as "made with butter" or features pictures of strawberries on the label, the amount of those highlighted ingredients must be disclosed.(7)
  • "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."(8) This provision applies when the composition of products that are marketed under the same name vary from one Member State to another.(9)

     The EU directive requires that the quantity indicated be expressed as a percentage and correspond to the quantity of the ingredient or ingredients at the time of use.(10) This information "shall appear either in or immediately next to the name under which the foodstuff is sold or in the list of ingredients in connection with the ingredient or category of ingredients in question." (11) When the declaration accompanies the product name, it is not required that the declaration be on the principal display panel or that the lettering be of a particular size. It is sufficient that the information be provided with the product name anywhere on the label, as long as the information is easily visible, clearly legible, and indelible.(12)

     U.S. law only requires QUID labelling for a few commodities (such as fruit and vegetable juice, peanut spread, olive oil blends, and seafood cocktail).(13) 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.(14)

     Nonetheless, U.S. food manufacturers, as well as manufacturers around the world, comply with the Thai and EU requirements when they export foods to those countries. In so doing, they confer a benefit to consumers in those countries while denying the same information to consumers in other countries.

IV. The Current Codex Standard:

     The current Codex standard is significantly weaker than the EU and Thai standards. The Codex standard only requires the declaration of the percentage of ingredients whenever the food label places special emphasis on the presence or low content of a "valuable and/or characterizing" ingredient.(15) A reference in the name of a food to a particular ingredient does not in itself constitute "special emphasis," nor is percentage labelling required merely if a reference is made to an ingredient that is used in a small quantity or only as a flavouring.

     The current Codex standard should be revised to provide consumers with better information about the ingredients contained in food products. Amendments to the current standard should be based on the best aspects of the EU and Thai QUID requirements which provide consumers with a high level of protection. As consumers around the world come to depend more and more on pre-packaged processed food items, such information becomes increasingly important.

V. 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 shall disclose the percentage, 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 declared on the product label as a numerical percentage adjacent to each respective ingredient listed 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 emphasized ingredient shall be reported on the label either:
     

      (a) in close proximity to the words or images emphasizing the particular ingredient, or

      (b) beside the common name of the food, in lettering that is at least 50% as large as the common name.
       

    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.

References

1. Codex Alimentarius Commission, Report of the Twenty-Third Session, Rome, 28 June - 3 July 1999, para. 202.

2. OFFICE OF AGRICULTURAL AFFAIRS OF THE USDA/FOREIGN AGRICULTURAL SERVICE, THAILAND: FOOD AND AGRICULTURAL IMPORT REGULATIONS AND STANDARDS (Fairs) 9 (July 1997).

3. 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).

4. Id. at Article 7(2)(a).

5. Ministry of Agriculture, Fisheries and Food, Draft Guidance Notes, July 1997, United Kingdom, Sec. 13 & 15 (hereinafter Draft Guidance Notes). The guidance notes are for purposes of providing informal, non-statutory guidance on QUID and should not be taken as an authoritative statement or interpretation of the law.

6. Directive 97/4/EC at Article 7(2)(b).

7. Draft Guidance Notes, supra note 5, at Sec. 16.

8. Directive 97/4/EC at Article 7(2)(c).

9. Draft Guidance Notes, supra note 5, at Sec. 18.

10. Directive 97/4/EC at Article 7(4).

11. Id. at Article 7(5).

12. Draft Guidance Notes, supra note 5, at Sec. 41.

13. 21 C.F.R. 101.30, 102.23, 102.37, 102.54 (1999).

14. See 58 Fed. Reg. 2,865 (1993).

15. CODEX ALIMENTARIUS COMMISSION, Codex Alimentarius Vol. 1, Section 5.1 (1995).