Clean Labelling: a brief overview of the most important EU regulations

The following EU regulations have been drafted for end consumers as well as for restaurants, hospitals, schools, canteens, and similar food service establishments. They are the legal basis for the manufacture and labelling of Clean Label Products:

• The Food Information Regulation (Regulation (EU) 1169/2011) governs the labelling of all foodstuffs, both on the label and, for example, in advertising. The most important principle is “the fair information practice" or, in other words: "Food claims should not be misleading to consumers".

• The Health Claims Regulation (Regulation (EC) 1924/2006 on nutrition and health claims made on foods) was established in 2007 and covers all nutrition and health claims for foodstuffs across the EU. It applies for nutrition and health claims made in commercial communications in the form of labelling and presentation, or in the advertising of food.
  
  In principle, all claims are prohibited unless explicitly permitted by this regulation. For example, the requirements for "low-sugar", "low-fat" or "low-calorie" products are defined in the nutrition claims.
  
  The health claims all require a list or individual approval. The list registrations - and denials - are published in a database. Thus, food business operators can already see in advance which claims are allowed or have already been rejected. The approved claims can be used by all food business operators.
  
  Anyone wishing to promote their product with a new, unlisted claim must, according to the Health Claims Regulation, undergo a rigorous process of verifying that the promise of a specific health effect from a particular ingredient of the food is fulfilled.

• The Flavouring & Additive Regulation (Regulation (EC) 1334/2008 and Regulation (EC) 1333/2008) declares exactly what are considered as flavourings or additives and what are not. In "1333", the list of all additives authorized in the EU is listed by food category with their "E number". Generally, an additive may be indicated with either the clear name or the E number in the list of ingredients. As the short E-number leads to some consumers to irritation or even rejection of the food, the food companies and the retail food sector mainly use the plain names. All additives and flavouring substances will be assessed by the European Food Safety Authority (EFSA) prior to approval and, if found safe, may be authorized with maximum use.
  
  Anything that falls under labels such as "no preservatives", "no colourings" or "no flavourings" must not contain any of the substances mentioned in these regulations.
  
  

Clean Label Products must meet the following additional criteria:

• Additives that are effective only in ingredients
  If an additive is contained in an ingredient that is no longer effective in the product itself, it must not be labelled on the final product in accordance with the Food Information Regulation and the Additives Regulation. In this case, it must be checked in each case whether this must be taken into account for the "without" or "free from" marking.

• Limit values from the EU regulations
  For certain claims - for example "sugar-reduced" - the requirements and, if applicable, limit values of the EU regulations must be complied with.

• Forbidden ingredients do not count
  It is forbidden to advertise the non-usage of ingredients that are prohibited by law. In this case the claim has to refer to the legal requirements, such as: 'Without flavour enhancers according to law'. 

• For potential double effects, the concrete application case counts
  Some additives can have several functions - for example, the citric acid has an effect on taste (as an acidifier), but in the consumer understanding, usually it has also a “preserving” effect because acidic foods usually do not spoil so quickly. Nevertheless, it is not a preservative within the meaning of the Additives Regulation. Thus, foods containing citric acid may be labelled with the words "no preservatives" unless they contain other preservatives.
  
  Although yeast extract has a flavour enhancing effect, it is not an additive in the legal sense. Here it must be checked individually, if it is better to claim “without flavour-enhancing additives” instead of “without flavour enhancers”.

Transparency and good information are the keys to a successful Clean Label Product!

Clean Label as an opportunity

The desire for healthy, natural, and tasty food stems from diet-related illnesses, food scandals, and heightened consumer awareness of what they eat every day. This is where Clean Label starts. Advertising must be in accordance with all laws and must not be misleading.