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When the same substance is used as both a nutrient enhancer and a food additive, how should it be labeled?
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Release time：2017-12-12 11:18
How should substances allowed in food, such as vitamin C, vitamin E, and lutein, be labeled on food labels, given that they can be used as both food additives and nutritional fortifiers?
1. Labeling in the ingredient list
According to the Q&A of GB 7718-2011, Article 37:
Ingredients that can be used as food additives or food nutritional fortifiers and also as other ingredients should be labeled according to their function in the final product. When used as a food additive, it should be labeled with the name specified in the "Standards for the Use of Food Additives" (GB2760); when used as a food nutritional fortifier, it should be labeled with the name specified in the "Standards for the Use of Food Nutritional Fortifiers" (GB14880); when used as other ingredients, its corresponding specific name should be labeled. For example, riboflavin, vitamin E, and polydextrose can be used as both food additives and food nutritional fortifiers. When used as food additives, they should be labeled with the names specified in the "Standards for the Use of Food Additives" (GB2760); when used as food nutritional fortifiers, they should be labeled with the names specified in the "Standards for the Use of Food Nutritional Fortifiers" (GB14880).
According to the Q&A of GB 14880-2012, Article 19:
Any one of the following three methods can be used for labeling: 1. Indicate the compound name (indicated by the name under the compound source in Appendix B or Table C.1); 2. Indicate both the nutrient name and the compound name; 3. Indicate the nutrient name (indicated by the name under the nutrient fortifier in Appendix A or Table C.1). Following international labeling practices, manufacturers are encouraged to use methods 1 and 2 above in the ingredient list.
2. Labeling in the nutrition facts table
According to the Q&A of GB 28050-2011, Article 16:
Prepackaged foods using nutritional fortifiers should, in addition to the labeling stipulated in standard 4.1, also indicate in the nutrition facts table the content of the nutrient after fortification and its percentage of the nutrient reference value (NRV). If the fortified nutrient is not within the scope of Table 1 of this standard, its labeling order should be listed after the nutrients listed in Table 1, but no requirements are made for its order.
Substances that are both nutritional fortifiers and food additives, such as vitamin C, vitamin E, β-carotene, riboflavin, and calcium carbonate, should be labeled according to this standard with their content and NRV% (no NRV% needs to be labeled if there is no NRV value) if used as nutritional fortifiers according to GB14880; if used only as food additives, they may not be labeled in the nutrition label.
It needs to be clarified here that the content in the nutrition facts table refers to the content in the finished product and has no relationship with the amount of nutritional fortifier used.
Article 17 of the Q&A in GB 14880-2012 provides a clear explanation:
The amount of nutritional fortifier used refers to the actual amount allowed during production. This amount takes into account factors such as the background content of nutrients in the fortified food, the nutritional status of the population, and food consumption, and is determined comprehensively based on the basic principles of risk assessment.
Given the large differences in the content of various nutrients in different food raw materials, and the different attenuation and loss of different nutrients during product production and shelf life, the actual content of fortified nutrients in the final product may be higher or lower than the amount of nutritional fortifier specified in this standard.
The combined use of GB28050-2011 and GB 14880-2012 is conducive to the reasonable fortification of nutrients and ensures the authenticity of the nutrient content in the final product and the consumer's right to know.
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