Food Labelling
New Food Labelling and Advertising Regulations
Compiled by Gabi Steenkamp, Registered Dietician, Johannesburg
(Sept 2007)

With the third draft of the South African food labelling regulations having just become available, it would be prudent to design labels and advertising of new products with the proposed regulations in mind. At present our advice is based on the published third draft of the regulations, and some of the finer details may still change.

See the government website www.SAGazettes.co.za for more details.

Why new legislation?

In the past, South African food manufacturers have used marketing strategies that mislead the consumer, not only directly with blatent untruths printed on labels, but also by misleading the consumer with half truths or by implication.

A good example of this are the vegetable oils that are labeled 'contains 0% cholesterol', when in fact all vegetable oils DO NOT contain cholesterol. By implication, consumers would then assume that only those oils labeled with the 'contains 0% cholesterol' are the healthier choice as only they contain no cholesterol.

To address these problems, the Food Directorate of the Department of Health, has been hard at work reformulating the Food Labelling Regulations.

Food Labelling example

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Below is a brief summary of some of the regulations pertaining to the labelling and advertising of foods in South Africa.

MANDATORY INFORMATION

	Name and address of the manufacturer or importer or distributor
	Instructions for use
	Net contents
	Country of origin
	Batch identification
	Use by date
	Nutrient analysis

This must be in table form per 100g of product as eaten (or if not, clearly stating per 100g of dry product) or per 100ml for liquids.

Per portion nutrient analysis is voluntary, if no nutritional claims are made.
	Ingredients must be listed in order of descending mass (not volume) i.e. the ingredient weighing the most will be listed first and the ingredient weighing the least will be listed last.
	All allergens must be identified in the prescribed format

DESCRIPTIVE WORDS

The following words may no longer appear on any food product:

	x% fat free
	nutritious
	healthy
	healthful
	wholesome
	complete nutrition
	balanced nutrition
	…….and other words implying the same thing
	The words “Sugar free” and “Fat free” are only allowed, if specific conditions, as stipulated in the new draft of the Food Labelling Regulations, are met.
	The words 'suitable for those with diabetes', 'diabetic friendly' or words with a similar meaning, may only be used if all criteria stipulated are met. (e.g. low GI, lower fat, controlled sodium, etc.)

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CLAIMS

	Provision is made for specific claims with specific wording that must be included on the label and/or advertising of the product. Many of these may well change in the final regulations as this is a hotly debated topic.
	If any claim is made, certain provisos must be met, the least of which is that the nutritional analysis of the product must be done by a reputable SANAS accredited laboratory, following accredited procedures as set out in the regulations. No calculated nutritional information is allowed in this case.
	In the case of the glycemic index (absorption rate of a carbohydrate containing food), this must be properly tested as set out in the regulations by a SANAS accredited organization.
	Glycemic index claims may only be made in the following categories; low GI , intermediate GI and high GI. No glycemic index values may appear on the packaging.
	Endorsement of a product may only be granted by an organization  where the endorsement programme is run by professionals, and where the specifications have been set up in keeping with the latest research. No company or member of the HPCSA may endorse its own products.
	The endorsement programme of DIABETES SA is run by the Glycemic Index Foundation of SA (GIFSA), which is run by qualified dietitians.

See the government website for more detailed information.

For a food labelling consultant, or food labelling workshops contact
Gabi Steenkamp

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SERVICES OFFERED:

Existing food label assessment

What is it?

All food labels in South Africa have to comply with the latest food labeling and advertising legislation in South Africa. We can check your labels to make sure that no regulations of the act are contravened. Should a complaint have been lodged against one of your labels or advertisements, we can assess where the error lies and how to correct it.

How do I go about it?

All food labels in South Africa have to comply with the latest food labeling and advertising legislation in South Africa. Submit your label to us and we will carry out a detailed assessment with regard to the latest food labelling and advertising legislation in South Africa. Upon receipt of your label, we will quote on the cost of the assessment. Once the quote has been accepted, a time frame will be worked out and the assessment will be carried out.

What do I get for my money?

Once complete you will receive: Detailed report with recommendations Detailed nutrition or function claims information, if requested Assistance with correct wording that may be missing or needs correction

What is it?

All food labels in South Africa must have certain mandatory (compulsory) information on the label. Depending on the product and the type of claims that one may wish to make, other information will have to be included as well. For new products, we will assist you in keeping within the law with all your wording on labels and in advertising material.

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