Health claims on drink/supplement labels in EU: Guide
Vitamin C contributes to the normal function of the immune system during and after intense physical exercise. It helps with the formation of collagen, allowing for the normal function of blood vessels, bones, cartilage, and even your gums.
Zinc contributes to the protection of cells from oxidative stress, has a role in the process of cell division, aids in normal DNA synthesis and acid-based metabolism, and even normal cognitive functions.
If your product contains Vitamin C or Zinc (or both), it would probably help sales if you were to integrate these claims into your label design and in accompanying marketing materials. And yet, so many products containing Vitamin C—and over a hundred other functional ingredients—are still sold today with barely such a mention on their labeling.
This is not because the ones that do are somehow unique and the companies behind them assembled scientific panels that performed studies, which they then passed on to the competent regulators (that’s the European Food Safety Agency, EFSA for short) in order to receive a special permit. It’s because they understand the value of such health claims on-label and the regulatory framework that sets the field for such statements and allows their usage.
A similar, but slightly different category is that of nutritional claims. Those are claims that characterize the product as a whole, and include the likes of High Protein, Low fat, Sugars-free or Low sugars, High Fiber, etc.
After a decade of working with functional drinks and supplements, I have enough practical experience to feel confident in the advice in this write-up. My aim is to acquaint you with EU regulation on foods (drinks, supplements, others) pertaining to health claims, hopefully attuning you to this often missed opportunity—one of the few major differentiating factors in an ocean of similar products.
This is a low-hanging fruit. You need only reach out and grab it.
The fruits of good science
The best part of the EFSA’s Health Claims regulatory framework is that it’s based on real, actual science, and not urban myth or popular delusions. There’s no pseudo-science to be found here—if the competent scientists that EFSA regularly calls upon to help substantiate plausible claims from rubbish form a binding opinion, they do so after quite extensive research into the available scientific literature. Here’s a link to what that looks like.
That is why most applications for a new addition to the Health Claims directory, often sponsored by companies that developed and manufactured the specific ingredient, end up being rejected—the science just isn’t there. I personally applaud this, as there’s enough misleading and cherry-picked information relating to health on the web as it is.
Regardless, you can make use of this regulatory mechanism to both increase sales, but as importantly—do so in a responsible manner, without having to feel guilty about possibly misleading your customers by relying on shaky science.
The opportunities here are vast, so where does one start? To make this more relevant to your context, let’s consider the two common starting points: yet unreleased new products, and existing products that do not feature health claims that can boost sales.
New products
Let’s start with your next product. It’s just an idea in your head at this point, and perhaps you’re looking for a partner like AMATA to help you bring it to market. What’s key in this instance is that it is not yet available to the public.
This is obviously the ideal starting point, as you don’t have to re-do the labeling and marketing of an existing product that you just now realize can be made more attractive to customers by making use of health claims.
Still, to move forward whilst incorporating this opportunity is a process. And it requires some serious consideration.
For starters, your product idea might feature dozens of functional ingredients, and you likely included them because of their known benefit to consumers. Since most of the approved health claims for specific ingredients usually number a half dozen or more, you can see how the design challenge can quickly grow complicated when you have a bunch of functional ingredients in your formula.
After all, you probably don’t want a label that is exclusively plastered with just health claims, but if there was a way to do it tastefully anyway, that would be preferable. You need a system, and to discern what should or shouldn’t be on the label. Further down, I’ll give you an example of how I personally managed this challenge, and hopefully that gives you ideas on how to improve on my approach.
Start here
Begin with researching the functional ingredients that you know that you want to be part of your product and whether you can make health claims about them. The linked database is easily searchable and will quickly give you an idea of the type of claims your ingredients allow for. Keep in mind that there are limits to avoid abuse—you can’t just put 10mg of Potassium in your beverage or supplement and claim a health benefit. The recommended daily intake of Potassium for adults is in the thousands of milligrams, so that makes sense. It has to be a certain minimum quantity depending on the ingredient to warrant the inclusion of such statements.
Let me help by nudging you in the right direction. Vitamin C, more specifically known as ascorbic acid, is one of the most ubiquitous ingredients used in nearly all beverages and supplements. Whether its use is intended to modify the properties of your product, or as a healthy fortification, is not as important as making good use of the doors it opens in terms of marketing. As I mentioned at the start of this article, Vitamin C plays a key role in just a multitude of the foundational processes that make our bodies tick.
I don’t mention Vitamin C as just a popular example. The reality is that most vitamins are, in fact, fairly inexpensive at this point. You can add a vitamin complex to your product and your production cost will barely register a change. That said, vitamins are not all there is to it—minerals, protein, collagen, fiber, probiotics and prebiotics, the list of available functional ingredients on the market is long and you should research if they warrant an on-label health claim.
Finally, I think health claims allow for a more guided, based in science, approach to formulations. In other words, you can target a specific necessity, such as bone health or nail or hair health, and tailor your recipe to include the ingredients proven to be of practical benefit. This, more structured approach, sometimes allows you to more clearly define the parameters of your product and work from the bottom-up.
Other examples would be products that target categories such as the immune system, fitness/sports, “beauty”, cholesterol management, sleep aids, etc.
Existing products
It’s an imperfect world. You might be here, reading this article, and realizing the opportunities that on-label health claims within the EU offer, all the while your product is already shipping to customers. In this case, there’s not much to be done—you simply have to start from scratch with your label design and marketing.
As mentioned in the above section, re-shuffling your design layout as to accommodate these statements is easier said than done. Not only do you have to consider how you can truncate the full claim messages to preserve space, but it might also be the case that the available claims are so many as to make it very, very hard to make full use of them.
I won’t claim to have cracked the code and to have found the ultimate answer. But a product we produced was in a very similar spot. This example presents just one possible way you can manage the task, but hopefully it gives you ideas that will help build upon and improve it.
Universal language
It does not exist.
In its stead, us humans continue to attempt to communicate via universally-understood signs and icons. The vast majority of people understand that a neon-yellow triangle sign with a skull inside cautions danger. And a crossed-out left arrow signals that left turns are forbidden.
That’s where I personally started, because it quickly became obvious that fitting all the claims on a label that, by law, is required to feature a bunch of other compulsory information and markings, would be impossible.
I chose icons. They convey information in a small form factor, allowing me to fit a bunch of claims that would otherwise have to be truncated.
I won’t claim that I nailed the problem and my solution is perfect. While it certainly made it possible to communicate a large swathe of information relating to health benefits, some of the icons ended up a bit too abstract due to the nature of the claims themselves. I know this to be true, as subsequent user testing revealed that some of the signage was ambiguous or poorly recognized to mean what it was supposed to mean.
This reveals the reality of product design: it’s a complex task that requires careful consideration.
Nutritional claims
Finally, let’s talk about nutritional claims.
As mentioned in the beginning, these are different from health claims. With the latter, as we’ve discussed, you’re allowed to claim certain health benefits stemming from the inclusion of certain ingredients. Nutritional claims, on the other hand, are a characterization of the product viewed as a singular whole.
As a reminder, this includes nutritional claims such as Low Energy, Low Fat, Low Sugars, High Fiber, High Protein, etc. As with health claims, certain limitations apply to ensure that products aren’t gaming the system.
An example of this is would be the requirement for at least 20% of the energy value of a food to be provided by the protein inside in order to qualify for a nutritional claim of High Protein. A smaller, 12% of the total energy being taken up by proteins inside your drink or supplement would only qualify them for the Source of Protein badge.
Similarly, if your product contains Omega-3 fatty acids, you can claim it’s a Source of Omega-3 Fatty Acids if at least 0.3g alpha-liolenic acid is present per 100g/100kcal, or at least 40mg of the sum of eicosapentaenoic acid and docosahexaenoic acid per 100g/100kcal. Along those lines they go, and so “No Added Sodium/Salt” would put a requirement that your product contains no more than 0,12g of Sodium or the equivalent value for salt, per 100g or 100ml.
You can check the comprehensive list of allowable nutritional claims in the EU, as well as the applying conditions, HERE.
Conclusion
Parsing EU legislature is never an exactly pleasant task. I have outlined some of the main points, and I believe them to be a good starting point, but do keep in mind that it’s your responsibility to ensure that you’re using health and nutritional claims within the strict confines set by law. If you’re unsure, you should seek qualified advice.
I personally consider health and nutrition claims to be among the few remaining so-called low-hanging fruits when it comes to differentiating your product from the competition. Despite this, approach this opportunity with care and a plan. Simply plastering claims on your label is unlikely to be the best strategy—your aim should be to create holistic messaging in your label design and marketing materials so that you can extract the highest return on your investment.
If you’re unsure on how best to do that, I invite you to shoot us a message, and we’ll be happy to help you capture the opportunities outlined in this article with your next Private Label product manufactured by AMATA.
No comment yet, add your voice below!