Food label claims are becoming more and more popular as food manufacturers seek a business advantage over competitors, satisfy corporate vision statements, or to meet the particular needs of a food consumer niche. It seems that the marketing department loves to make claims on the product packaging and labels. For the QA department, this can be a source of stress especially since they have to be the ones who provide the ‘proof’ for the food claim being made.
This post explains what a food label claim is, the different types of claims, and the significance of not complying with regulatory requirements. It also provides practical methods to help you and your food business to verify the product claims that appear on your food packaging.
Table of contents
- What is a food label claim?
- Types of Food Label Claims
- Legal Compliance
- Verifying food label claims
- The Natural Effect
- Take action
What is a food label claim?
From my research it was difficult to find an absolute definition for a food label claim. My best description is a mark applied to a food label, packaging or associated advertising that asserts or declares that a particular attribute associated with that food is true. This is my high-level definition. When you read on you will see more granular definitions that related to different types of food product claims.
Types of Food Label Claims
There are many different types of food product claims with examples often overlapping groups. Product claims can be loosely categorised as:
- Nutritional content
- Religious or philosophical
- Assurance – sustainably caught, GlobalG.A.P,
Nutritional content claims
Nutrition Content claims relate to individual nutrients in a particular food product. Examples include ‘low in fat’, ‘high in protein’, ‘good source of calcium’, no added sugar, ‘low carb’. These types of claims are regulated within countries like Australia, New Zealand, the USA, Canada, Europe, and the United Kingdom.
Health-related claims go deeper in associating a health benefit obtained from consuming a particular food. They link a particular nutrient or substance in the food with an effect on health, or to a serious disease, or biomarker of a serious disease. Some examples include:
- Fibre keeps you regular
- Phytosterols may reduce blood cholesterol
- Adequate calcium and vitamin D as part of a healthful diet, along with physical activity, may reduce the risk of osteoporosis in later life
- Omega-3s can help reduce risk of hypertension
Like nutritional claims, health-related claims are regulated by many countries globally.
Religious or philosophical
Religious or philosophical-based claims not only relate to people’s religious adherence but also overlap other personal and ethical values. Examples can include Kosher, Halal, Vegan, Vegetarian, Plant-based.
Ethical label claims
Ethical-based claims continue to rise as manufacturers tap into meeting the needs, values, and morals of their consumers. Research released by Euromonitor International shows that North America and Western Europe are the largest ethical label markets. Examples of ethical claims often relate to human and animal fairness like fair trade, workforce labour issues, sustainable palm oil, free-range.
Ethical trade and responsible sourcing management system
BRCGS has an ‘Ethical Trade and Responsible Sourcing‘ standard that enables suppliers to demonstrate that the goods and/or services that they sell are produced ethically and that raw materials are sourced responsibly.
Provenance claims related to a country, geographical region or place of origin. They may also be known as “Country of Origin” statements. Rules around provenance claims are often embedded in food labelling legislation. Examples include Atlantic Salmon, Champagne, Cognac, Roquefort cheese.
Assurance based claims
The ACCC defines Assurance claims that refer to ‘specific systems or processes that have been put in place to provide assurances to specific consumer groups/tastes. Claims may be substantiated through well-documented certification processes performed by authorised persons. Examples include sustainably caught, GlobalG.A.P, cage-free
Identity preserved claims are referenced by both BRCGS and SQF certification standards. BRCGS defines identity preserved as being “a product which has a defined origin or purity characteristic which needs to be retained throughout the food chain (e.g. through traceability and protection from contamination). Labelling a product as ‘Organic’, ‘Free-from’ or ‘Gluten-free’ are examples of identity-preserved claims. Many of the examples provided within this post may also sit under the umbrella of identity preserved foods.
Characteristic based claims
These types of claims imply a relationship with a particular standard and can include example words like ‘pure’, ‘fresh’, ‘real’ or genuine.
Process based claims
Processed based food labels refer to a specific process, preparation or production system related to the final product. Examples can include ‘baked not fried’ ‘flame-grilled’, ‘sun-dried’, ‘non-GMO’, ‘no artificial colours or flavours’.
In most countries, there are specific laws around making food claims. Please ensure that you refer to applicable food safety and food labelling laws in your country of origin and the country where you are going to export your food product. If you are certified to a GFSI recognised standard there are auditable requirements around labelling and food claims.
If you make false or misleading food product claims you may find your business faced with some hefty court action and financial impacts.
Examples of False and Misleading Food Product Claims
In April 2009, Kellogg Company in the USA, agreed to a settlement of $4million dollars after they were charged by US Federal Trade Commission with making a false advertising claim on their Frosted Mini-Wheats cereal. The claim stated that the product was “clinically shown to improve kids’ attentiveness by nearly 20%”.
More recently, a game farm located in Australia was recently fined over A$20,000 after it made claims on its product packaging and its business website that their birds were “range reared”, when in fact they were grown in commercial sheds with no access to the outdoors.
Baiada, another Australian based company, made a similar claim stating that its birds were free to roam in large barns. $400,000 in civil pecuniary penalties were ordered to be paid in this case of false and misleading advertising.
Verifying food label claims
The majority of certification standards will have requirements around the protection and verification of identity preserved food. Here is the method that I use to verify the food label claims made by food businesses.
- Get a copy of the food label or printed artwork.
- Review the label and write out a list of all the different food claims made.
- Cross reference each claim to any relevant legislation. The purpose of this step is to make sure that you are complying with the law.
- Gather any evidence that backs-up your claim. Evidence can include external test reports, supply declarations from raw material suppliers, in-house testing results.
- Compare the evidence that you collected in the previous step against both the actual label and the applicable law.
- Document your findings. Make sure that you record the result and references obtained during this activity.
- Rinse and repeat whenever there is a change to your food label, the law, your raw materials or advisory from your approved supplier.
The Natural Effect
During a review of things happening in the food industry I came across a really funny video about using the word “Natural” in advertising. The following video is a parody of using claims on food packaging. It gave me plenty of laughs and really highlighted what I sometimes see as a food auditor (sad but true). Enjoy!
Now is a good time to have a look at the product claims that you make on any of your products. For each product, map the evidence and records that supports the claim and have this information on file. You can do this by undertaking a mini food audit of the food label claim.
To help you with your food label compliance check out the following HACCP Mentor resources