Addition of vitamins and/or minerals

The conditions specified for the use of nutrition claim "added [nutrient]" in the Annex to the Claims Regulations do not enable the use of a claim stating "added vitamin/mineral".

However, recital 20 in the Claims Regulation states that "Any claim considered to have the same meaning for consumers as a nutrition claim included in the aforementioned list should be subject to the same conditions of use indicated therein".

  • For example, claims related to the addition of vitamins and minerals such as "with …", "restored …", "added …", or "enriched …" should be subject to the conditions set for the claim "source of …".

In Evira's view, the inconsistency is caused by reasons related to translation. The English version of the Claims Regulation uses two terms for claims related to addition; "added" and "increased [NAME OF NUTRIENT]". In the Swedish version these are translated "tillsatt" and "Ökat innehåll av [NAMN PÅ NÄRINGSÄMNET]". In the Finnish translation both are translated with "Lisätty" (added).

Because of this, Evira is of the view that:

  • Claims referring to the addition of vitamins and minerals in foods (pursuant to Regulation (EU) No 1925/2006), such as "restored [name of vitamin and/or mineral] ", "increased [name of vitamin and/or mineral] and "added [name of vitamin and or mineral]" can be considered to have the same meaning as the claims "with" or "…source of" if the products meet the conditions set for the claim "source of…".
  • However, the claim "increased [vitamin and or mineral]" may not be used for purposes of comparison to similar products, because the conditions set for the use of the claim "increased [nutrient]" rule out this possibility for vitamins and minerals. Because of this, comparative nutrition claims such as "more vitamin C", "50% more calcium" or "vitamin D doubled" may not be used.