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Guideline on Labelling Requirement under the Food Act 1983 and Food Regulations 1985




These guidelines provide comprehensive guidelines on nutrition information, food labeling requirements, nutrient content claims, compliance criteria, and regulations related to food products in Malaysia.


It emphasizes the importance of accurate labeling to provide clear information to consumers and ensure compliance with regulations.


The guidelines cover a wide range of topics such as nutrient function claims, labeling of irradiated or genetically modified foods, minimum amounts required for health claims, and the importance of nutrition labeling for consumer information and product competitiveness.


What are the key guidelines outlined in the document regarding making nutrient content claims on food labels?

The key guidelines outlined in the document regarding making nutrient content claims on food labels include:


  1. Understanding Permitted Claims: Food manufacturers must be aware of the types of nutrient content claims that are allowed and the specific conditions under which these claims can be made. This includes knowing the types of claims and the required conditions for each type of claim.

  2. Prohibited Claims: Certain claims are explicitly prohibited, such as claims that food provides an adequate source of all essential nutrients, claims that cannot be substantiated, and claims suggesting that food can prevent, treat, or cure diseases.

  3. Additionally, claims that cause consumers to doubt the safety of similar foods or exploit fear are not allowed.

  4. Voluntary Nutrition Labelling: Foods not required to have mandatory nutrition labeling can still list their nutrients, provided they comply with the format and requirements stipulated in the nutrition labeling and claims regulations. The mandatory nutrients that must be declared include energy, protein, carbohydrate, and total sugars.

  5. Comparative Claims: When making comparative claims about the nutrient content of foods, the difference in energy or nutrient content between the compared foods must be at least 25%, and the minimum absolute difference must meet the value required for a claim as “low in” as stipulated in the regulations.

  6. Use of the Word “Nutritious”: The use of the word “nutritious” or similar terms in food advertisements is restricted to foods that meet specific criteria regarding the range of nutrients they contain, their energy content, protein content, and the presence of at least four vitamins and two minerals.

  7. Conditions for “Source of” or “High in” Claims: The document specifies the minimum nutrient content required for a food to claim it is a “source of” or “high in” certain nutrients, such as protein, vitamins, and minerals. These conditions are based on a percentage of the Nutrient Reference Value (NRV) per 100 g, 100 ml, or 100 kcal.

  8. Comparative Claims for Unlisted Nutrients: Nutrients not listed in the specified appendices for making nutrient content claims are not permitted to make nutrient comparative claims. This is because there are no established conditions for these nutrients to meet the requirements for making such claims.

These guidelines ensure that nutrient content claims on food labels are accurate, substantiated,


How do the guidelines specify the requirements for labeling food products that have been irradiated or contain genetically modified organisms?

The guidelines specify the requirements for labeling food products that have been irradiated or contain genetically modified organisms (GMOs) as follows:


1. Irradiated Foods: Packages containing irradiated food for sale must bear a written statement indicating the treatment. The statement can be in one of the following forms: “TREATED WITH IONIZING RADIATION,” “TREATED WITH IRRADIATION,” “TREATED BY IRRADIATION,” or “IRRADIATED”.


2. Genetically Modified Organisms (GMOs):

  • For food and food ingredients composed of or containing GMOs, the label must include the words “genetically modified (name of the ingredient)”.

  • If the food and food ingredients are produced from but do not contain GMOs, the label should state “produced from genetically modified (name of the ingredient”.

  • The labeling requirements apply only to the three main ingredients in the ingredient list. Foods containing, consisting of, or produced from GMOs in a proportion not more than 3% of the food ingredients considered individually or food consisting of a single ingredient, provided that this presence is adventitious or technically unavoidable, are exempt from these labeling requirements.

  • For single-ingredient foods, the GMO information should appear on the principal display panel near the name of the food and in not less than 10-point lettering. For multi-ingredient foods, the GMO information should appear in the list of ingredients immediately following the ingredients. Additionally, the statement “contains the genetically modified ingredient” must be stated on the principal display panel close to the name of the food and in not less than 10-point lettering.

These requirements ensure that consumers are informed about the presence of irradiated components or genetically modified organisms in their food, allowing them to make informed choices.


Why is accurate nutrition labeling important for both consumers and manufacturers according to the guidelines provided in the document?

Accurate nutrition labeling is important for both consumers and manufacturers for several reasons according to the guidelines provided in the document:


1. For Consumers: Accurate nutrition labeling provides consumers with essential information about the nutritional content of food products, enabling them to make informed choices regarding their diet and health.


It helps consumers understand the contents of the products they are purchasing and assess their quality, thereby aligning with their health and dietary needs.


2. For Manufacturers: For food manufacturers, accurate nutrition labeling serves as a powerful tool to differentiate their products in the market by highlighting the nutritional qualities of their products. It also enhances the product profile and provides an effective communication tool between the manufacturers and consumers. Furthermore, accurate nutrition labeling can increase international trade opportunities by ensuring compliance with the nutrition labeling regulations of different countries, thereby making their products more globally acceptable.


Moreover, implementing proper nutrition labeling and claims can benefit the food industry by increasing its competitiveness in the market.


Accurate labeling is also crucial for manufacturers to ensure that they comply with the regulations and avoid misleading consumers, which is essential for maintaining consumer trust and avoiding legal issues.


Conclusion

Businesses in the food industry should take the following advice to ensure compliance and leverage the benefits of accurate food labeling:


1. Stay Informed and Compliant: Regularly review and stay updated with the Food Regulations 1985 and any amendments to ensure all products meet the current legal requirements for labeling and advertising. This includes understanding the specifics of labeling for irradiated foods, GMOs, and making nutrient content claims.


2. Utilize Labeling Services: Consider using the available services such as self-screening, independent consultants, label screening, and label advisory services offered through the Fosim System to ensure compliance. These resources can provide valuable guidance and prevent potential regulatory issues.


3. Emphasize Transparency: Be transparent in labeling and advertising practices. Declare all ingredients, allergens, country of origin, and any treatments such as irradiation or genetic modification. This transparency builds trust with consumers and can differentiate your products in a competitive market.


4. Highlight Nutritional Benefits: Accurately calculate and declare the nutritional content of your products. Use nutrient content claims (e.g., "low in" or "free of" certain nutrients) responsibly and only when they meet the specified criteria. This not only complies with regulations but also caters to the growing consumer demand for healthier food options.


5. Educate Your Consumers: Use food labels and advertising as tools to educate consumers about the nutritional benefits and quality of your products. Clear, accurate, and informative labels can help consumers make informed dietary choices, enhancing customer satisfaction and loyalty.


6. Ensure Quality Control: Implement rigorous quality control measures to ensure that the nutritional content of your products is consistent with what is declared on the labels. This is crucial for maintaining compliance and avoiding penalties.


7. Prepare for Global Markets: If you're considering international trade, ensure your product labeling meets the requirements of the target markets. Accurate nutrition labeling and adherence to international standards can open up new opportunities and increase competitiveness.


8. Monitor and Adapt: The food industry and consumer preferences are constantly evolving. Stay attentive to trends, such as the increasing interest in non-GMO and minimally processed foods, and adapt your product development and labeling accordingly.


By following these guidelines, businesses in the food industry can not only ensure compliance with current regulations but also position their products favorably in the market, catering to the health-conscious consumer and leveraging accurate labeling for competitive advantage.


Reference:

351. Garis Panduan Pelabelan 2023
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