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CInternational Food Labeling The Committee was cognizant of the larger environment in which U.S. food labeling reform was being considered. Sensitivity to the trends and developments in other countries is important in a world where trade and national economies depend on the ability of companies to sell goods on the international market. This Appendix briefly discusses the current guidelines of the European Community, the Codex Alimentarius Commission, and the results of an informal survey conducted to better understand the situation in specific countries. EUROPEAN COMMUNITY The efforts to create a single market by the end of 1992 for the 12 nations of He European Community (EC) will have an enormous impact on the composition of food products and on their labels. Many companies have already created and started advertising "Eurobrands," single brand names for products sold throughout Europe (Prokesch, 1990~. In anticipation of this unified market, the Council of the European Community (the Council) recently adopted the Directive on Nutrition Labeling for Foodstuffs (the directive), which is a common position on nutrition labeling of food products that is a prelude to Be establishment of a standardized format that will apply in all EC countries (CEC, 1990~. The Council was inspired by the same concerns that are driving U.S. food labeling policies: the growing public interest in the relationship between nu~idon and long-term heals, the need for nutrition education of the public, and He need to improve diet to improve heals. In its preamble to the directive, 313

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314 APPENDIX C the Council noted that to appeal to He average consumer, "given the current low level of knowledge on the subject of nutrition, the information provided should be simple and easily understood" (CEC, 1990, p. 3~. The directive creates guidelines for voluntary nutrition labeling. Labeling would be mandatory only when a nutrition claim appears on a food package or in an advertisement for the product. Nutrition claims (descriptors) would be restricted to those related to calories, protein, carbohydrates, fat, fiber, and 18 vitamins and minerals. The directive applies to foodstuffs to be delivered ultimately to consumers and to products intended for mass caterers, such as restaurants and hospitals. Natural mineral or other waters intended for human consumption and diet integrators/food supplements are exempted Nonpackaged foodstuffs sold ultimately to consumers or mass caterers and food products packaged at the request of the purchaser or prepackaged with a view to immediate consumption are to be covered by the laws of individual EC countries until the eventual adoption of measures for the EC as a whole. Two formats for nutrition information are outlined in the directive, either of which may be used when nutrition labeling is voluntary or required. The first format includes only calories and protein, carbohydrate, and fat (in grams). The second adds sugars, saturated fats, fiber, and sodium. If a nutrition claim is made for sugars, saturated fatty acids, fiber, or sodium, the label must include the expanded format. In addition, a manufacturer may include information on starch, polyols, monounsaturated and polyunsaturated fatty acids, cholesterol, and any of the 18 vitamins or minerals, for which there are RDAs, that are present in significant amounts. A nutrition claim may be made for a nutrient only if the food provides 15 percent of the RDA. If the label lists polyunsaturated and/or monounsaturated fatty acids or cholesterol, it must also list the amount of saturated fatty acids. Calories are to be described in a numeric format, expressed per 100 g, per 100 ma, or per 100 ml. The directive also allows the use of graphic formats in addition to Be numerical listing, if permitted by the member country. In declaring sugars, polyols, or starch, the following format must be used: - carbohydrate (g), of which: - sugar (g) - polyols (g) - starch (g) Assessment of the amount or Me of fame acid or cholesterol must imme- diately follow the declaration of total fats, in Me following format: - fat (g), of which: - saturates (g) monounsaturates (g) polyunsaturates (g) - cholesterol (mg)

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APPENDIX c 315 Declared values must be based on averages, as calculated from the (1) manu- facturer's analysis of the food, (2) the known or actual average values of the ingredients used, or (3) generally established and accepted data The directive gives ample time for compliance by member countnes. Within 18 months of final adoption of the directive, trade in complying products will be permitted. Three years after adoption, products that are not in compliance with the directive will be prohibited from trade. However, the requirements for labeling of sugars, saturated fatty acids, fiber, and sodium will not take effect for 5 years (CEC, 1990b). The directive also addresses the powers of individual countries to add to its requirements: "Member states shall refrain from laying down requirements more detailed than those already contained in this directive concerning nutrition labeling" (CEC, 1990a, p. 14~. CODEX ALIMENTARIUS COMMISSION The Food and Agriculture Organization of the World Health Organization (FAD/WHO) established the FAD/WHO Codex Alimentarius Commission in 1962 (hereinafter referred to as Codex) to implement the Joint FAD/WHO Food Standards Program. As of June 1986, the Codex had 129 member countries. Codex guidelines for food labeling are outlined in the Codex Alimer~arius (FAD/WHO, 1987~. The announced purposes of these guidelines are to provide consumers with information so they can make wise food choices, to encourage improved formulation of foods, and to prevent deceptive nutrition labeling (EAO/WHO, 1987~. Codex guidelines contain advisory criteria and standards for the nutrition labeling of foods. The guidelines state that nutrient declarations should be mandatory on any food for which a nutrition claim is made (Codex sections 3.1- 5.1), but voluntary for all other foods. When provided, energy value and amount of protein, available carbohydrate (not fiber), fat, and any other nutrient for which a nutrition claim is made should be declared. A carbohydrate claim also triggers the disclosure of total sugars. If a fatty acid claim is made, then saturated and polyunsaturated fatter acids should be declared. Vitamins and minerals present in significant amounts, defined as 5 percent of the recommended intake, should be declared only for those for which there are recommended intakes or those that are of nutritional importance to individuals in a particular country. Nutrient content is to be presented in a numeric format, but additional depictions, such as graphics, are not prohibited Information should be expressed per 100 g, 100 ml, or per package if it contains a single serving. Information may be provided per serving if the total number of servings is stated. Vitamin and mineral information may be expressed in metric units and/or as a percentage of the Recommend Dietary Intake (RDI) per 100 g, per 100 ml, or per package if it contains a single serving. .,

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316 APPENDIX C The guidelines prescribe a specific format for carbohydrate disclosure: - Carbohydrate (g) X(B) - of which sugars (g) Total carbohydrate may be followed by x (g), where x represents the specific name of any other carbohydrate constituent. For fatty acids the specified format is as follows: - Pat ~) - of which polyunsaturated (g) - and saturated (g) The Codex guidelines include provisions for supplementary information to be given in addition to the nutrient declaration mentioned above. Recognizing that there are individuals in the population who are illiterate and/or have little knowledge of nutrition, the guidelines suggest food group symbols or other pictorial or color presentations. Consumer education programs are urged to enhance nutrition labeling. Also recommended is a periodic review of nutrition labeling to keep pace with health information. SURVEY OF FOOD LABELING IN OTHER COUNTRIES In 1990, the Committee sent a questionnaire (see box) on two occasions to 32 respondents in 27 countries. Twenty-one replies to the first questionnaire were received from 18 countries and 10 replies to the second questionnaire were received from 10 countries. The countries included Belgium, Bulgaria, Canada, Denmark, Finland, the Federal Republic of Germany, Israel, Japan, Luxembourg, Monaco, The Netherlands, Norway, Portugal, Spain, Sweden, the United Kingdom, and He USSR; a reply was also received from He Council of the European Community. Eight respondents were members of the EC and, as such, they reported using the labeling provisions expected to be adopted in the near future. A brief summary of all responses is found in the survey summary box. OBSERVATIONS ON INTERNATIONAL FOOD LABELING As a result of this review, it is clear that there is a great deal of interest and activity in nutrition labeling in other industrialized nations. Most of this activity is inspired by the same concerns about diet and long-term health that led to the formation of the Institute of Medicine committee and to the interest in nutrition labeling by U.S. federal agencies and the U.S. Congress. Even in nations with comparable standards of living, however, food produc-

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APPENDIX C 317 l Questionnaire Sent to Officials Working in me Field of Food and Nutrition in 27 Countries To Determine International Food Labeling Practices all? 1. Does your country have any regulations or guidelines concerning labeling at Yes No Do Not Know 2. Whose responsibility is it to informs users (i.e., those who decide on the design of labels) about these regulations or guidelines? (Name and address of responsible institution) 3. Please list the main groups of foods/commodities covered by labeling require- ments, and indicate whether these are mandatory or voluntary. 4. What is the scope of the labeling regulation/guidelines? Do they cover ingredient listing? Yes No Do Not Know Do they cover nutrient presentation? Yes No Do Not Know Do they cover claims on foods or descriptions of foods? Yes No Do Not Know ng: 5. What do the regulations/guidelines say about presentation of labeling concern- Use of graphics or symbols Use of numbers (percentages, relative numbers, servings, other) 6. What are the reasons for choosing one mode of presentation over another? 7. Which nutrients are included in the presentation and why? 8. Does your country have an "officially" endorsed set of dietary guidelines? Yes No Do Not Know 9. Have labeling requirements been designed to correspond with the message in the dietary guidelines? Yes No Do Not Know 10. Do you have available any studies of how consumers perceive and use labeling? Yes No Do Not Know If the answer is yes, could you please let the nutrition unit of the WHO Regional Office for Europe have a copy?

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318 APPENDIX C Summary of Responses to the 1990 Survey Sent to 27 Countries Purposes of Labeling The countries that responded to the questionnaires indicated that the purposes of nutrition labeling are to convey information to consumers to enable them to improve their diets, allow consumers to compare products and choose the better alternative, provide infor- mation for general health promotion purposes, avoid misleading information, standardize messages, and provide general information without further specification. Responsibility for Labeling Regulations Institutional responsibility for labeling regulations among the countries that responded to the questionnaire varied and included ministries of health, trade, or agriculture; consumers; and the national food agency. In most countries, however, ministries of health are responsible for nutrition labeling. Announcements of nutrition labeling requirements are generally made through some type of official gazette. Food Supply Coverage All countries reported that they have some form of food labeling regulation or guidelines. Ingredient labeling is mandatory and covers either all foods or all prepackaged foods. Ingredients that are required to be listed on food labels are specified. Nutrition labeling is voluntary in most of the responding countries except when nutrient-related claims are made, in which case it is mandatory. Several countries limit the types of claims that are allowed. A few countries have plans to implement mandatory nutrition labeling. Relation to Dietary Guidelines Six countries responded that they have publicly approved national dietary guidelines and that nutrition labeling requirements are designed to correspond with those guidelines. However, several countries did not explicitly state that national dietary recommendations and regulation of nutrition labeling are connected. Presentation of Labeling All European respondents use the metric system or percentages in nutrition labeling. Only Canada recently changed to using '~per serving" as a basis for nutrition labeling. Three countries and the EC permit the use of per serving as a basis for nutrition labeling, but they also allow metric units. Nutrients Covered Most countries reported inclusion of the following items when nutrition labeling is used: energy, fat, protein, and carbohydrate. Few countries require vitamins or minerals in nutrition labeling, and in most countries, listing of vitamins and minerals is optional. Consumer Studies Studies on consumer perception of labeling were reported to have been conducted in half of the countries that responded to the questionnaires. Those studies were conducted in conjunction with the adoption or revision of nutrition labeling regulations.

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APPENDIX C 319 lion and sales data display different dimensions. Mass catering has a larger role in Europe, where many workers are fed on the job. Sales of food at limited- menu restaurants are nowhere as significant a part of food sales as they are in the United States. Europeans are literate with regard to the metric system, whereas the U.S. population is resistant to changing from the English system. Advertising of foods is more prevalent and perhaps less controlled in the United States than it is elsewhere. Food variety is probably greater in the United States. Foods must bear labels that meet local legal requirements. Fobs produced in Europe for sale in the United States must bear labels that meet U.S. regulations and vice versa Very few foods bear precisely the same label worldwide, and this is likely to remain Rue for the balance of the twentieth century. Thus, the United States needs its own system. The U.S. system, however, should be designed keeping in mind the interesting innovations that have been tried in other countries, to the extent that such innovations are consistent with domestic requirements, consumer desires, and dietary recommendations. REFERENCES CEC (Council of the European Communities). 1990a. Common Position Adopted by the Council of European Communities 1990 with a View to the Adoption of a Directive on Nutrition Labeling for Foodstuffs. European Council, Brussels. 17 pp. CEC (Council of the European Communities). 1990b. Reexamined proposal for a Council Directive on nutrition labeling of foodstuffs. European Council, Brussels. 6 pp. FAD/WHO (Food and Agriculture Organization of the United Nations, World Heals Organization). 1987. Codex Alimentarius, vol. VI, 2nd ed. Food and Agriculture Organization of the United Nations, World Health Organization, Rome. Prokesch, S. May 31, 1990. Eurosell Pervades the Continent. The New York Times. p. D1.