You want to boost your product with powerful ingredients like lion's mane mushroom, ashwagandha, or turmeric, or ginseng? But what can you actually say on your label? Welcome to another episode of the Food Lab Podcast. I'm your host, Manon Galizzi. And today, we are starting our series about nutrition and health claim, and more precisely, which ones you can use and where to find them.
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I find that nutrition and the health claims are probably one of the most challenging thing you can have in the food legislation.
So I think it's really important to have this episode to just clarify a few things. And a few things to clarify is what is a nutritional claim and what is a health claim? So a nutrition claim is any positive nutritional impact that a food or drink will have and is based on the quantity of the nutrient. So you will have, for example, this food or this drink is high in protein, low in fat, source of calcium and no added sugar. And for each term you use, you will have a specific quantity that is required.
So high in protein, low in fat. You can't just pick these words and think, oh, yeah. It has to be very, very specific. It has to be based on calculations.
The health claim, on the other hand, is anything that a nutrient will have a benefit on our health.
So it's much more difficult to, how do you say that? It's more difficult to prove. Here we go. That's the word. French French French brain today.
So, so for example, you will have Vitamin A contributes to the normal function of the immune system. You will have magnesium contributes to the reduction of tiredness and fatigue. And again, it has to be a lot of scientific data. It has to be approved and is based on certain quantity of the nutrients to be able to use that claim on your packaging.
So where can you find these nutritional and health claims?
Well, the first thing to know is they have to be approved and authorised by a certain country. So now The UK is out of the EU, the UK has its own committee to be able to double check the claims that you can use in The UK. And this is the UK Nutrition and Health claims committee UKNCC, which is now detached from the EU.
But they have to be authorised and approved by The UK being on a certain register for you to be able to find them and use them. And again, like I said before, they have to respect a certain quantity, certain conditions in term of which exact ingredient you can use, how much can you use it, and are you allowed to use it in any food or drink, basically.
But all of these takes a long time. I will talk about the "on hold" claim. So they have to be authorised by the government. And basically, the government, The UK or the EU, haven't done any more approving of these claims for about ten years. It takes a very long time, and that's why there's not a lot of gut health claims for example, you can find.
You can't have claims around specific groups of food or drinks, or you can't really just say something very generic, "Oh, yes, vegs and fruits are very good for your health". That doesn't work. Every claim you do need to be very specific.
And like I mentioned before, the claims are not sexy. They are just mentioning what they are doing on the body and the mind for your health. So like I said before, magnesium contributes to the reduction of tiredness and fatigue. There's nothing more than that. Most of them would just say contribute to the normal function of the immune system.
And we'll talk about the rules in a few minutes, but that is one of the thing that you can't expect this health claims to be sexy. You can change them slightly in terms of wording, but you can't mislead the consumer.
You can't say "your energy is gonna boost 10 times", "You're gonna have so much more focus". For example, focus is used in a lot of packaging, especially when some functional ingredients like lion mane's mushroom or ashwagandha are used.
It's not allowed. There's nowhere in any health claim mentioning focus as a word. You can't use that. And most people use it. It's not exactly what the claim says.
It has been reword because it's very sexy to think, oh, we can focus more, but it's not really how the wording works.
So they have to be scientifically based and approved by the government for you to be able, to use them. And, again, it's to avoid misleading the consumers. So for The UK, you can find all of these claims, the approved ones, and you can also find the non-approved one in the Great Britain nutrition and health claim register. So, again, be careful because it's a huge spreadsheet.
And on the far right of the spreadsheet, you can actually select the ones that you want to see. So I always recommend to select the authorised ones because you may think, oh, yes. It's in the register, so they're all approved. No. No. No. No. No.
It's a little bit of a legacy document, especially since The UK have left the EU. So you will find updated things that were approved at one point but not approved anymore.
So just be sure you select the approved ones. So the way the document look like, it divided in two sections. You have the health claim in one tab of the Excel spreadsheet, and you have the nutritional claim on the other side of the spreadsheet. And most of the time, health claim relate to nutritional claim.
So a health claim can say, for example, if you want a source of something or if you want to mention this is low fat, you have to refer to the nutritional claim to ensure that the right amount of that ingredient is allowed to be able to use the health claim. It will make more sense. In another episode, I will do in the following weeks, I will explain exactly how to calculate the nutritional claims and the health claim, especially when it's related to vitamins and minerals because it's much more complicated. So today, we're not diving into how to calculate. I'm just informing you where to find the information.
So just bear in mind that health claims, most of the time, is related to nutritional claims, so they talk to each other.
The last one to look at is a weird one. It's called "on hold" claim. So this is a very strange one, especially when you have something that is so rigid as a huge spreadsheet on the register to be able to see the authorised and the non authorised attrition and health claims. So it's very black and white.
It's authorised and not authorised. On the "on hold" claims, on the other hand, is a very, very grey area. So it's a different spreadsheet that you can also find on the UK government website, and I will put the link in the description of the episode.
And how do you say that? Basically, "on hold" claim, you will find most of the botanicals or any substances that you won't find on the normal, classic health and nutrition claim register.
So it will be anything like caffeine related. You will have amino acids. You will have ashwagandha. You will have most of the botanicals. So, basically, what happened in this case, if anyone find that on the standard, health and nutrition claim from the government, like, for example, there is nothing about turmeric.
Fine. So I do all of my research, and you have to find when you do the application form, you have to provide all of the scientific reviews and literatures that you've gathered to be able to pull the claim that you want to submit. So I've done all of my research. I have few literature document that mentioned how good turmeric is good for the health. I have exactly what sort of health claim that I can submit.
Let's say, for example, contribute to the normal function of the immune system and things like that. So you submit the application form mentioning all of the scientific literature reviews. Sometimes can ask how much of the ingredient you need because that's also the problem.
Most of the "on hold" claims never mentioned how much of an ingredient is good to be able to contribute to something healthy in our body. So for example, it's good to say, like, turmeric.
Yes. There are some molecules in turmeric that, yes, contribute to the health benefits. But how much turmeric do you actually need to eat to be able to see the health benefits on your body? And this is what sometimes is very misleading. So you can see a lot of marketing.
I'm not gonna say propaganda because it's a big word, but there is a lot of marketing push to say that pumpkin seed is amazing. Turmeric is amazing, ginger is amazing, and it probably is. But if there is no certain quantity of these ingredients to be used and how to use them, then you will never be able to actually see the health benefits. It has to be linked to a certain quantity. So anyway, let's go back to "on hold" claim.
So "on hold" claim, from what I've seen, hasn't been updated in about ten years. So I've done this research for one of my clients recently, and we were looking at all of these amazing ingredients like turmeric and ginger and baobab and all of these amazing things. There were absolutely none. And this is because the document hasn't been updated in more than ten years. So maybe submission have been done to the different governments, either the EU and The UK, about turmeric and all of these incredible plants.
But the document is still dated from, I think, 2011, if I'm not mistaken. But the problem is these claims have been there for more than ten years, and none of the government had a look at them. So they are not non authorised, but they are not authorised. They're just here in limbo waiting for decisions to be made. And the thing is, as long as a decision hasn't been made and they are in this limbo, anyone can use these claims.
And I think this is why it's so so so dangerous, and this is why you can see a lot of claims around ashwagandha because ashwagandha is on the "on hold" claim register. So it doesn't mean it has been authorised by the government that they looked at the literature reviews and they thought, yes. Ashwagandha, we approved. Doesn't mean that at all. It just means these claims are in limbo.
They're just waiting for the governments to take decisions on them. So anyone can use these claims. But when I look at them, you can definitely tell anyone have just submitted a claim. And when you look at the wording, it's just absolutely nonsense, and it doesn't respect what the food legislation say about wording of a health claim. It will say things like, "it will increase massively", "It's so good for you", "It will increase your longevity", "It will make your health so much better".
You are not allowed to say that. This is so vague and so misleading for the consumers.
You're not allowed. So if ever you use the "on hold" claim register, you have to reword whatever it says on the claim and double check that is in accordance to the food legislation and what they're saying about "contribute to the normal function of" or "increase" or "help reduce fatigue", for example.
You really have to take all of the wording of the approved claim and try to make it match. And again, like I said, all of these "on hold" claim don't have anything about quantities. So you will have something like, oh, yes.
Ginger is very good for you and it boosts your immune system. How much do I need to use in my product? Doesn't say. Doesn't say. So how someone like me who develop product for clients, I have no idea.
I can't just put a little bit of ginger in there and say, I can do an "on hold" claim. It's just for me, it's just ludicrous to be able to have that system and to be able to say to everyone, yes. Of course, you can use all of these "on hold" claim until one of the government says, oh, no. By the way, you can't see them. Or, oh, yes.
They are validated, but you have to use this in a certain way.
So really, really, really be careful. And I always say to my clients who want to do this kind of "on hold" claim is to be sure you do your own research. You have to back up with a lot of literature reviews because if the food legislation come at you and say, "well, you've made a claim about ashwagandha or ginger, Can you show me where did you take this information from?"
"Where are your scientific proof?" So you always have to back up. And, again, if you want to use under certain quantity to use the "on hold" claim, I would advise you to have a look at the scientific review and see what they say and the amount that that they use. But for me, personally, I would just say stay away. I know it's frustrating.
Don't get me wrong. It's very frustrating that none of the government are taking this in their priority. Nutrition has never been, like, this kind of priority. So it is very frustrating that this document hasn't been updated. Almost none of these claims have been either approved or not for a very, very long time.
So I feel your frustration that you can't use this claim on your packaging. But they will be my advice. Be very careful or do not use this "on hold" claim.
So there are rules to remember whenever you use a nutritional and health claim, and they are very important to know, but they're not very obvious. So very important.
Let's start with number one. A health claim can't mention that they prevent, they treat, or they cure disease or any medical conditions or they refer to a specific amount of weight loss. You can't do that. You have to use the wording of a claim that you're using.
Two, claims have to be followed by a statement showing the importance of varied and balanced diet and healthy lifestyle.
And this is to avoid consumers to just use your product thinking, oh, yes. It has vitamins. It has minerals. It has a lot of things in it. That's it.
This is my healthy diet. I'm just gonna use that product. So it's also to say, our product has very functional ingredients, is good for you, but don't forget to have also a healthy lifestyle around it.
Number three, add the statement if your product may present health risk if consumed in excess and mention the person who should avoid using your product. And that's mainly for a pregnant woman, for example, or if anyone has any health condition that can just interfere with a medication or treatment.
Number four, you can't use health claim with alcoholic drinks with more than 1.2% ABV. And again, that makes sense, isn't it? We do not want to promote alcoholic drink in that sense. Alcoholic drink, by definition, is not a healthy product. We know even a little bit how much it can damage our health, how much it can damage our mood, and our sleep.
So having a few drinks from time to time, no problem at all. No problem at all. But we can't promote it suddenly as a healthy product. It will be the same as cigarette. Be like, "oh, you know what? If you have cigarette, we have added minerals and vitamins to our cigarettes, so it's good for you". No. No. No. This is not not allowed at all.
Number five, the claim shall refer to the final ready to eat product or ready to consume in accordance with the manufacturer's instruction. So if, for example, you have a powdered drink, you have to do all of your calculation to be able to know the amount that is in the final product. Biscuits is when the product is ready to eat, to consume, or to drink. So it's the same with protein shake, for example, if you had water to it and things like that. So you always have to refer to the ready to consume product.
And six, claim wording can be changed, but never false, exaggerated, ambiguous, or misleading. So we had that conversation, before you have I know they are not sexy, but you have to stay true to the claim. You can reward it a little bit, but just very slightly because as soon as you mislead the consumer, you may have problems. You think about the consequences if the food legislation find out or if someone mention it to the food legislation. You will damage your reputation.
You will damage the trust that the consumers put in your product, in your brand. That would do a lot of damage. So rather than just overselling something and exaggerating with the claim, just stay true. Build the trust with your consumer.
So if indeed some that's why some people use only words rather than the full sentences.
So you always have to put the full health claim sentence, which can be very, very long, but you always have to put it somewhere in your packaging. But if you want to just have keywords like immune system, tiredness, and fatigue, These kind of things to attract a consumer and avoid them to read very long sentences, that is fine. But, again, avoid things like "focus" and other very exaggerating like "boost" or "good for your health", "good for you", and things like that just doesn't mean anything.
And, again, you have to think about how consumer are gonna perceive your product. Again, you don't want to everyone to think that your product is the key for healthy lifestyle and this is the only product that they need.
And if they had your product, then that's it. They have a healthy diet and things like that. You have to put things in perspective according to how they eat, how they live, and things like that. You have to be very careful.
Another important point is lab testing and overages.
So again, I always advise my clients when they want to do nutritionals and health claim, once they've done their theoretical calculation and everything on paper looks like it should be fine, you should have the right amount to be able to support your nutritional or health claim, I always suggest it's not compulsory, but always suggest to reach out to a laboratory and test the nutritionals and especially over shelf life.
Because if, for example, your product has six months shelf life, everything in your, packaging, all of the ingredients will interact with each other. They will interact with the packaging and the condition they are in, so you never know also how, the product are gonna be stored. So always ensure that if you say your shelf life is six months, at the end of your six month shelf life, your product should still have the same amount of vitamins and minerals. And I know it sounds crazy because it probably won't be but you have to.
Someone that buys your product almost at the end of its shelf life and someone that buy at the beginning of shelf life should have the same product. This is the guarantee that you're saying to your consumer. Whatever is six months shelf life, whenever you buy this product, you will have the same nutritional and health benefits.
So you really have to do this sort of nutritional test across the shelf life and maybe you will have to do what we call overages which is that you have to increase a little bit more of the ingredients or the nutrients at the beginning of your shelf life. So when it decreases, it will have the right amount, until the end.
So it's basically better to have a little bit more than what it says on the packaging than less because that will clearly be misleading. If it's a little bit more and it's not, like, massively more or anything like that, that's absolutely fine. It's better to have a little bit more, but to be sure that the quantity you're putting on your packaging is there rather than having almost nothing compared to what you are saying.
So there, all of this, lab testing can be a bit expensive, but is they are so worth it. Because this is your due diligence to be sure that what you're saying on your packaging, on your website, the way you communicate with your consumers is true.
Again, you want to build trust. You want to be authentic and real with them, assuring them that this is the this is the real deal. This is exactly you will have this amount in the product, whatever the shelf life.
And the last point for today is about nutritional labeling. So anything you put on your packaging related to the amount of ingredients, amount of nutrients, and things like that.
So if you find the right nutritional and health claim, you have the right amount of ingredients, you have it lab test it. Now it's time to put everything on your packaging.
So if you do a nutritional or health claim, it's mandatory to mention the nutrient in your little nutrition labeling, the table that you have. So you have to mention the substance name and their quantity. And if it's a vitamin or a mineral, you also have to mention the percentage of daily recommended intake (RI).
So again, it's very clear the consumers will have all of the information in the right space and underneath this little table, for example, this is where you put whatever is the nutritional claim or the health claim but they have to appear them on your packaging and on your website.
Again, on your website, you should have the same information as your packaging. And I'm still shocked sometimes to see that. Loads of food and drink business do not mention the ingredient list. They do not mention the nutritionals of their product.
This is a requirement by the food legislation. By law, you have to indicate to your consumers what is in your product before they buy it. And something that happened to me when I do some research and I want to buy a product, if I see a product but I don't see the ingredients list or the nutritionals, whatever I'm interested in, I'm not gonna buy it. Literally, I'm not gonna buy it. I'm not interested of paying for this product if I don't know what is in it.
So you have to mention to your customers, and it's very important even just for allergens. That is a requirement for the food legislation. So basically, whenever you have this information on your packaging or on your website, don't forget to put all of this information on, again, on your web page or directly on your labeling.
To recap this episode, we saw the difference between nutritional and health claim, the wording of these claims, and what's the difference between them, but actually how they work together, where we can find these claims in the proper register, and be sure they are authorized in the, Great Britain nutrition and health claim register or on the European register. We talked about the on hold claim and the debate that create in the community, especially around food scientist and how you can use them but maybe not use them.
We saw the six rules to bear in mind and incorporating your product in a healthy diet and healthy lifestyle, especially if you want to promote nutritional and health claim.
We talked about doing some, lab testing and overages to be sure that at the end of your shelf life, your products still have the amount of the nutrient that you mentioned so you can still support your claim and you're not misleading the consumers.
And at the end, we saw where to put this information on your labelling and on your website.
The next episode, we'll be talking more specifically about nutrient and health claim related to vitamins and minerals because they are so much more complicated than any other ingredient and how to calculate the right amount to support your claim. Thank you for listening.
If you got value from this episode, follow the podcast and subscribe to my newsletter for more tips and knowledge about food and drink product development. And I will see you in the next episode. Bye.
