The presentation of the nutritional labelling referred to in the Food Information Regulation does not apply to food supplements. Instead, the amount of characteristic substances in the food supplement must be presented in accordance with the Food Supplement Decree. If a nutrition or health claim is made on a food supplement, the amount of the substance on which the claim is based must be presented, however in the list of characteristic ingredients or in connection with it.
Pursuant to Section 5 of the Food Supplement Decree of the Ministry of Agriculture and Forestry (78/2010), the labelling of food supplements shall indicate that the food supplement is not to be used as a substitute for a diversified diet. Article 10(2)a of the Claims Regulation, on the other hand, requires that a statement indicating the importance of a varied and balanced diet and a healthy lifestyle is included in labelling, or if no such labelling exists, in the presentation and advertising of foodstuffs.
The requirement laid down in the Claims Regulation applies also to food supplements, and thus in Evira's view the sentence referred to in the Food Supplement Decree does not alone fulfil the requirement of the Claims Regulation. The labelling of food supplements shall also include a statement referring to a balanced diet and a healthy lifestyle.
- In Evira's view, the following sentence, for example, fulfils the requirements of both Section 5 of the Food Supplement Decree and Article 10(2)a of the Claims Regulation: "A food supplement is not to be used as a substitute for a varied and balanced diet or a healthy lifestyle".
- The content of this message can be divided into two separate sentences, if desired.
Pursuant to the Claims Regulation, the quantity of the food and the pattern of consumption required to obtain the claimed beneficial effect shall be indicated in the labelling of the food, or if no such labelling exists, in the presentation and advertising. The conditions set for the use of health claims often specify the quantity of the substance on which the claim is based per 100 g or 100 kcal. These conditions for use cannot be directly applied to food supplements which are consumed in small doses and typically have a low energy value. For this reason, Evira is of the view that for food supplements the limit value shall be specified per daily dose.
- The following health claim has been authorised for alpha-linolenic acid (ALA): "ALA contributes to the maintenance of normal blood cholesterol concentrations".
- The specific conditions of use of this health claim are the following: "The claim may be used only for food which is at least a source of ALA as referred to in the claim "source of Omega-3 fatty acids" as listed in the Annex to Regulation (EC) No 1924/2006. Information shall be given to the consumer that the beneficial effect is obtained with a daily intake of 2 g of ALA." A claim that a food is a source of Omega-3 fatty acids may only be made, where "the product contains at least 0.3 g alpha-linolenic acid per 100 g AND per 100 kcal, or at least 30 mg of the sum of the eicosapentaenoic acid and docosahexaenoic acid per 100 g and per 100 kcal."
- Evira is of the view that this health claim can be made for a food supplement that contains at least 0.3 g alpha-linolenic acid per daily dose, or at least 40 mg of the sum of the eicosapentaenoic acid and docosahexaenoic acid per daily dose. However, information shall be given to the consumer that the beneficial effect is obtained with a daily intake of 2 g of alpha-linolenic acid.
- Evira recommends that information be given to the consumer of the daily dose of the food supplement, or the daily dose of the food supplement and some other food containing alpha-linolenic acid required to obtain the claimed beneficial effect