What are the permitted nutrient function claim for Vitamin A, Vitamin D and Vitamin E in Sri Lanka, Malaysia, China, Philippines and Vietnam? Is there any specific condition should be meet in order to make such claim?

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  1. Ricebowl Food Expert
    May 27, 2019 at 9:44 am

    Sri Lanka

    According to Food (Labelling and Advertising) Regulation 2015, health claim/s or nutrient function claim/s shall be permitted that all of the following conditions are met:

    • Any food for which a nutrient content claim, a nutrient comparative claim or a health claim is made shall have Nutritional Labelling
    • All Health claims should have prior written approval by the Chief Food Authority
    • Only those essential nutrients for which a Nutrient Reference Value has been established in Schedule V of these regulations shall be subject of a nutrient function claim

    These claims can be made when the foods are a “source of” or “high in” Vitamin A, vitamin D & vitamin E as specified in table below:

    Item Content Claim Mode Content demand
    Vitamin Source at least 15% of NRV per 100g (solids)
    at least 7.5% of NRV per 100ml (liquids) or
    at least 5% of NRV per 100kcal (12% of NRV per 1
    M J) or 15% of NRV per serving
    High 2 times the values for “sources”

    Table below is the list of Nutrient Reference Value (NRV)

    Nutrients Components NRV
    Vitamin A 800 µg
    Vitamin D 5 µg
    Vitamin E 10 mg aTE

    Reference:

    • Ministry of Health Sri Lanka. (2015). Food (Labelling and Advertising) Regulation 2015

     

    China

    According to GB28050-2011 National Food Safety Standard for Nutrition Labelling of Prepackaged Foods, Nutrient Function claim is permitted when the nutrient component meets the requirement and conditions of content claim.
    Table below are permitted nutrient function claim for Vitamin A, Vitamin D and Vitamin E:

    Nutrient Permitted Nutrient Function Claim
    Vitamin A
    • Vitamin A helps maintain the scotapia
    • Vitamin A helps maintain the health of skin and mucosa
    Vitamin D
    • Vitamin D facilitates the absorption of calcium
    • Vitamin D helps maintain the health of bone and tooth
    • Vitamin D helps the formation of bone
    Vitamin E
    • Vitamin E has anti-oxidation effects

    Remark: No excision, adjunction and mergence in any form to the expressions of function claim should be made.

    These claims can be made when the foods are a “source of” Vitamin A, vitamin D & vitamin E as specified in table below:

    Item Content Claim Mode Content demand
    Vitamin Origin of vitamin X or including vitamin X  /100 g ≥ 15% NRV
    /100 ml ≥ 7.5% NRV   or
    /420 kJ ≥ 5% NRV

     

    Table below is the list of Nutrient Reference Value (NRV)

     

    Nutrients Components NRV
    Vitamin A 800 µgRE
    Vitamin D 5 µg
    Vitamin E 14 mg α-TE

    Reference:

    • National Standards of People’s Republic of China. (2011). National Food Safety Standard for Nutrition Labelling of Prepackaged Foods (GB28050-2011).

     

    Vietnam

    According to No.34/2014/TTLT-BYT-BNNPTNT-BCT Joint Circular on guidance on the labeling of goods for foods, food additives and packaged food processing aids, claim as source or rich source if the nutrient is present as below:

    • As vitamin and mineral supplements: Providing 15% of nutrient reference value in 100g (solid) or 7.5% of nutrient reference value in 100ml (liquid). Providing 5% of nutrient reference value for 100 kcal (12% nutrient reference value for 1MJ) or providing 15% of nutrient reference value for a single serving.
    • High vitamins and minerals: Twice as much as the value of vitamin and mineral supplements

     

    Table below is the list of Nutrient Reference Value (NRV)

     

    Nutrients Components NRV Remark
    Vitamin A 800 (µg RAE or RE)
    Vitamin D 5 – 15 µg The value of 15 µg is based on minimal sunlight exposure throughout the year. Competent national and/or regional authorities should determine an appropriate NRV-R that best accounts for population sunlight exposure and other relevant factors
    Vitamin E 9 mg

    Reference:

    • Ministry of Health. (2014). No. 34/2014/TTLT-BYT-BNNPTNT-BCT Joint Circular on Guidance on the labelling of Goods for Foods, Food Additives, and Packaged Food Processing Aids.
    • Codex Alimentarius International Food Standards. (2011). Guidelines on Nutrition Labelling (CAC/GL 2-1985).

     

    Malaysia

    According to Food Regulation 1985, nutrient function claim can only be made provided the food meets the criterion for claims for “source of”.
    Table below are permitted nutrient function claim for Vitamin A, Vitamin D and Vitamin E:

    Nutrient Permitted Nutrient Function Claim
    Vitamin A
    • Vitamin A aids is maintaining the health of skin and mucous membrane
    • Vitamin A is essential for the functioning of the eyes

     

    Vitamin D
    • Vitamin D helps the body utilize calcium and phosphorus
    • Vitamin D is necessary for the absorption and utilization of calcium and phosphorus

     

    Vitamin E
    • Vitamin E protects the fat in body tissues from oxidation

     

    Remark: For all above claims, words/sentences of similar meaning can also be used

    These claims can be made when the foods are a “source of” Vitamin A, vitamin D & vitamin E as specified in table below:

    Component Claim Conditions
    Not Less Than
    Vitamin Source 15% of NRV per 100g (solids)
    7.5% of NRV per 100ml (liquids)  or
    5% of NRV per 100 kcal

     

    Table below is the list of Nutrient Reference Value (NRV)

    Nutrients Components NRV
    Vitamin A 800 mg
    Vitamin D 5 mg
    Vitamin E 10 mg

    Reference:

    • Ministry of Health Malaysia. (2017). Food Regulation 1985. Regulation 18

     

    Philippines

     

    According to the labelling guidelines of FDA Philippines, we follow Codex Guidelines and for Use of Nutrition and Health Claims (CAC/GL 23-1997) and Codex General Guidelines on Claims (CAC/GL 1-1979 rev. 1991).
    According to Codex Guidelines and Use of Nutrition and Health Claims (CAC/GL 23-1997), health claims should be permitted provided that all of the following conditions are met:

    • Health claims must be based on current relevant scientific substantiation and the level of proof must be sufficient to substantiate the type of claimed effect and the relationship to health as recognized by generally accepted scientific review of the data and the scientific substantiation should be reviewed as new knowledge becomes available. The health claim must consist of two parts:
      1. Information on the physiological role of the nutrient or on an accepted diet-health relationship; followed by
      2. Information on the composition of the product relevant to the physiological role of the nutrient or the accepted diet-health relationship unless the relationship is based on a whole food or foods whereby the research does not link to specific constituents of the food.
    • Any health claim must be accepted by or be acceptable to the competent authorities of the country where the product is sold.
    • The claimed benefit should arise from the consumption of a reasonable quantity of the food or food constituent in the context of a healthy diet.
    • If the claimed benefit is attributed to a constituent in the food, for which a Nutrient Reference value is established, the food in question should be:
      1. a source of or high in the constituent in the case where increased consumption is recommended; or,
      2. low in, reduced in, or free of the constituent in the case where reduced consumption is recommended.

      Where applicable, the conditions for nutrient content claims and comparative claims will be used to determine the levels for “high”, “low”, “reduced”, and “free”.

    • Only those essential nutrients for which a Nutrient Reference Value (NRV) has been established in the Codex Guidelines on Nutrition Labelling or those nutrients which are mentioned in officially recognized dietary guidelines of the national authority having jurisdiction, should be the subject of a nutrient function claim.

    These claims can be made when the foods are a “source of” Vitamin A, vitamin D & vitamin E as specified in table below:

    Component Claim Conditions
    Not Less Than
    Vitamin Source 15% of NRV per 100g (solids)
    7.5% of NRV per 100ml (liquids)  or
    5% of NRV per 100 kcal (12% of NRV per 1MJ)
    High 2 times the value for “source”

      

    Table below is the list of Vitamin Recommended Nutrients Intakes per day:

     

    Reference:

    • Republic of the Philippines Department of Health Bureau of Food and Drugs. (2007). Guidelines in The Use of Nutrition and Health Claims in Food Bureau 2007. Circular 2007-002.
    • Codex Alimentarius Commission. (2004). Guidelines for Use of Nutrition and Health Claims 1997. CAC/GL 23-1997, Rev.1-2004
    • National Nutrition Council. (2015). Adoption of the Philippine Dietary Reference Intakes (PDRI 2015): The Very First NNC Governing Board Resolution Approved for 2016.

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