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| Past Events |
Minutes of the Meeting held on 10th August 2007, Presented by Mr. D.S.Chadha |
Chairperson: Mr Debasish Panda, Joint Secretary, Ministry of Health & Family Welfare
The following members of the Expert Group as constituted by Ministry of Health were present:
- Mrs (Dr) Asha Thomas, Director, Ministry of Health
- Mr P S Chopra, ADG (PFA)
- Mr A K Srivastava, DADG (PFA)
- Dr B Sesikeran, Director, NIN
- Dr K N Gurudutt, Director, CFL Mysore
- Ms Indrani Kar, CII
- Mr D S Chadha, CII
- Ms Neha Aggarwal, CII
- Mr Sameer Barde, CIFTI/ FICCI
- Ms Aarti Gupta, CIFTI/ FICCI
Below is the note on the suggestions made by the CII and the views of the Government on each clause:
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A. Quantitative Ingredient Declaration |
| Present Definition |
Suggestions |
Reference Documents |
Government views as discussed on 10th August |
Rule 32 (b) (2) (iii): Every package of food sold as a mixture or combination shall disclose the ingoing percentage, by weight or volume as may be appropriate, of any ingredient at the time of the manufacture of the food (including compound ingredients or categories of ingredients) and if such ingredient-
(A) is emphasized as present on the label through words or pictures or graphics; or
(B) is essential to characterize the food in order to distinguish the food from other categories of food with which it may be confused; or
(C) is emphasized as ingredients in the name of the food; or
(D) the disclosure of which is deemed to be necessary to enhance the health of consumers or to prevent
consumers from being deceived, or
(E) is the subject of an express claim about the presence of any fruits, vegetables, whole grains or added sugars;
Provided that the above disclosure is not required where ingredients comprises less than 2% of the total weight of the product and has been used for the purposes of flavorings.
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The clause should be changed to:Rule 32 (b) (2) (iii): Every package of food sold as a mixture or combination shall disclose the ingoing percentage, by weight or volume (indicative value) as may be appropriate, of an ingredient at the time of the manufacture of the food (including compound ingredients or categories of ingredients), where such ingredient-
A. is emphasized as present on the label through words or pictures or graphics; or
B. is not within the name of the food, is essential to characterize the food and is expected to be present in the food by consumers if the omission of the quantitative ingredient declaration would mislead or deceive the consumer
The clause should be changed to:
Rule 32 (b) (2) (iii): Every package of food sold as a mixture or combination shall disclose the ingoing percentage, by weight or volume (indicative value) as may be appropriate, of an ingredient at the time of the manufacture of the food (including compound ingredients or categories of ingredients), where such ingredient-
A. is emphasized as present on the label through words or pictures or graphics; or
B. is not within the name of the food, is essential to characterize the food and is expected to be present in the food by consumers if the omission of the quantitative ingredient declaration would mislead or deceive the consumer.
Provided that such disclosure is not required:
(i) where such ingredient is used in small quantities (< 8%) for the purpose of flavorings
(ii) where such ingredient is emphasized in the specification of standardized products under the Act/ Rules e.g. Protein rich atta, Sugar Boiled Confectionery, Malt based foods, milk chocolate etc.
(iii) where an established trade or fancy name is provided at national/ international level
eg. Cream Cracker (no cream), Chicken/ Rajma masala (where no chicken/ rajma is present).
(iv) in heterogeneous products, as the dispersion of such ingredients will not be uniform, the quantitative declaration shall be considered as
a self regulation for the manufacturer and as an information to the consumers
(v) in the case of pictorial representations, clearly marked as “serving suggestions”
(vi) For foodstuffs where water is added in preparation but certain quantity is lost following treatment during processing shall correspond to the quantity of moisture/ water used, related to the finished product.
Guidelines will be provided By CII illustrating the above views based on the international practices. |
Our earlier suggestions to delete clause (C), (D) & (E) have been accepted by Codex at Step 5 (ALINORM 07/ 30/ 22 Appendix V) and Clause (B) has been modified to include the intent of clauses (C), (D) & (E) of original notification; hence it is proposed to retain clause (A) and replace clauses (B), (C), (D) & (E) as mentioned.
Current Codex QUID guidelines (Section 5.1 of General standards for Labelling of Pre-packaged Foods)
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1.MoH has considered the use of word ‘minimum’ instead of ‘indicative values’. Industry needs to review it.
2. MoH appears to be agreeable to insert ‘an’ instead of ‘any’ and replace ‘where such ingredient’ in place of ‘and if such ingredient’.
3. It was suggested that with the use of essence/ oleoresins, the amount may not exceed 2% but if the seeds or powdered form of flavouring substances is used, then 2% will not be an appropriate limit to set. However, Govt required justification for fixing the value at 8%. Industry to put reasons/ examples for the same.
4. As regards exemption of QUID for standardized foods, Govt has suggested that in order to familiarize the consumer with the quantity of the ingredient present as emphasized on the label, it should be mandatory to provide QUID even for the standardized foods. However, MoH has suggested the industry to review the same critically with due justifications.
5. For established names/ fancy names, MoH appears to be agreeable with the issue but has suggested the industry to draft a proper provision for the same in order to be transparent to the consumer with the ingredients present in the product. It was also suggested that industry may use quotes ( “ ) or similar punctuations to distinguish the ingredient which is present as a pictorial representation on the label, but not contained in the product.
3. Serving suggestions may be provided for the same.
4. As regards heterogeneous products where dispersion of ingredients may not be uniform, Govt has suggested that the consumer who is paying for the presence of an expensive ingredient, as emphasized, must be informed of the same and which should be present at some minimum quantity (or within a range) in each individual quantity of food.
5. Industry to provide suggestions.
(CII may suggest the use of powdered form of such ingredients in order to avoid this problem). Range to be suggested by the industry.
Government has suggested the industry to review Global perspective for above provisions.
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B. Nutritional Labelling |
| Present Definition |
Suggestions |
Reference Documents |
Government views as discussed on 10th August |
Rule 32 (b) (2) (iv): the complete nutritional information per 100 gm of the product shall be given on the label containing the following:
(A) information on energy value shall be expressed in Kcal per 100 gm or per 100 ml;
(B) information on the amounts of protein, carbohydrate and fat in the food shall be expressed in gm per 100 gm or per 100 ml;
(C) the amount and/ or type of fatty acids (including amount of saturated fatty acids, polyunsaturated fatty acids, monounsaturated fatty acids and trans-fatty acids) and cholesterol in gm per 100 gm or per 100 ml;
(D) numerical information on vitamins and minerals shall be expressed in metric units per 100 gm or per 100 ml;
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Should be mandatory only when a nutritional claim is made (As per CAC/ GL-2 - 1985/ Rev-2003)
Rule 32 (b) (2) (iv): The word ‘complete’ be deleted since the amount of naturally present nutrients is variable and not quantifiable.
The nutritional information will be indicative since the composition of raw agricultural products (wheat, rice, milk etc varies from region to region, animal to animal etc) e.g. Wheat in Punjab has protein content upto 11-12% whereas in other parts of the country, it may be 6-7% (100% variation). PFA prescribes a minimum of 6%. Same variations will be seen in the case of all other nutritional parameters.
Nutrient content will also undergo changes during processing, storage etc. As declared value will change, hence it will not be possible for a manufacture to comply with the law in its current form.
Hence it is not possible to give the complete (natural + added) nutritional information.
Further, the four core nutrients viz. energy, carbohydrates, proteins & fats, may be given for the composite products only on the basis of ingredients added at the time of manufacture.
For single products, only name of the product is required to be declared.
Hence clause (iv) will read as:
“an indicative nutritional information per 100 gm/ 100 ml (as appropriate) of the product shall be given on the label containing the following:
(A) information on energy value shall be expressed in Kcal per 100 gm or per
100 ml;
(B) information on the amounts of protein, carbohydrate and fat in the food shall be expressed in gm per 100 gm or per 100 ml;
(C) information on the amount of other nutritional factors such as type of fatty acids (Saturated, unsaturated and trans fatty acids), cholesterol, vitamins, minerals shall be expressed in metric units (as specified in CODEX) per 100 gm or per 100 ml; when a specific claim regarding these are made.
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Attention is invited to the Section 3.1.1 & 3.1.2 of Codex guidelines on Nutritional Labelling CAC/ GL –2-1985, Amend. 2005) Attention is invited to the Section 3.2.5 of Codex guidelines on Nutritional Labelling CAC/ GL –2-1985, Amend. 2005)
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1. Govt. did not agree to make nutritional labelling voluntary, however, it was considered to put “indicative’ or ‘minimum’ value keeping in view the variations due to geographical regions, processing etc.
2. MoH has agreed on the CII suggestion for providing four core nutrients. However, the industry is required to provide a critical justification and review to the above clause taking a global perspective on the same.
3. As regards the listing of types of fatty acids, CII explained the technical difficulty in order to examine the composition of types of fatty acids. Director, CFL Mysore also agreed to the problem of variation in the composition of fatty acids even at Codex level because of geographical reasons and availability of different types of oils in a particular season when blend of oil is used.
4. MoH has suggested to provide a minimum level of Trans fatty acids in foods.
5. Regarding the vitamins and minerals content, the MoH has considered the problem of varying composition of vitamins & minerals in the same category of food due to geographical variation of nutrient content in a food, processing & storage conditions etc. However, MoH has suggested the industry to procure more information on how such problems have been handled in other countries and draft a justified provision for the same.
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| CII suggests to provide detailed guidelines on the interpretation of different terms and intent of QUID/ Nutritional labelling taking into consideration national as well as international guidelines issued by EU, UK etc. |
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