Industry Codes of Practice

IMACE Code of Practice on Nutrition Claims

Code of Practice on Nutrition Claims (Update October 2004) [PDF] [HTML]
Ann 1 - Monounsaturated Fat Rationale [PDF]
Ann 2 - Polyunsaturated Fat Rationale [PDF]
Ann 3 - Nutrition Claims in Margarine/Spreads (and other categories) [PDF]
Ann 4 - Unsaturated Fat Rationale [PDF]
Ann 5 - Omega 3 Claims Rationale [PDF]
Ann 6 - Free of cholesterol - Claims Rationale [PDF]

Preface

Margarine and fat spreads play an important role in the diet of European consumers. Therefore IMACE member companies are committed to improving the nutritional quality of their products in line with nutrition science and providing information on the composition of their products to the consumer.
Nutrition claims have been used by the industry since 1965 and in the late seventies and early eighties a number of country associations developed their own Code of Practice for them. However in 1992, IMACE decided to standardise these and developed its first European Code of Practice on Nutrition Claims. In the last decade our knowledge of nutrition and health has dramatically increased, particularly in the area of fatty acids and it was therefore decided a revision of the Code was needed.
This Code of Practice lays down the conditions for the use of nutrition claims relevant to margarine and fat spreads as defined within Council Regulation 2991/94.
IMACE members are aware of the discussions and intention of the Commission to harmonise the area of nutrition claims. IMACE members support the principle of harmonisation of claims on a European scale and are confident that this Code of Practice can be a useful contribution to that aim.
This Code provides a harmonised European approach and IMACE members believe that applying the conditions of the Code will help to maintain consumer confidence in the nutrition claims made by our sector.

Anthonie Stal
President of IMACE

Member Associations

Members of IMACE are the national margarine associations in 22 countries of Europe.
The Member Associations of IMACE represent some 120 margarine companies throughout Europe. In 2001 their annual production of margarines and fat spreads amounted to a total of 2.191.301 MT.

List of the IMACE Members

Code of Practice on Nutrition Claims

ARTICLE 1 (Scope)
This code concerns nutrition claims based on fat/fatty acids as present in margarine and fat spreads, which will be delivered as such to the ultimate consumer.
The list of claims is not exhaustive, but includes the most commonly used nutrition claims within the Community, which are nutritionally relevant, and in accordance with the latest scientific knowledge.

ARTICLE 2 (definitions)
For the purpose of this Code:
a) “margarine and fat spreads” are those products referred to in Council Regulation (EC) No 2991/94 including the sales description defined in the Annex under B and C, which describes vegetable fat spreads and melange products.
b) “nutrition claim” means any representation and any advertising message which states, suggests or implies that a foodstuff has particular nutritional properties due to the energy (calorific value) it provides, provides at reduced or increased rate or does not provide and/or due to the nutrients it contains, contains in reduced or increased properties or does not contain [Article 1.4 Nutrition Labelling Directive 90/496]
c) c) Nutrients – all the definitions of the nutrients with the exception of unsaturates, trans and omega 3 are taken from Article 1.4 Nutrition Labelling Directive 90/446.

“Polyunsaturates” or “polyunsaturated fat” or “polyunsaturated fatty acids” (PUFA) means fatty acids with cis, cis-methylene interrupted double bonds

“Monounsaturates” or “monounsaturated fat” or “monounsaturated fatty acids” (MUFA) means fatty acids with one cis double bond

“Unsaturates” or “unsaturated fat” or “unsaturated fatty acids” (UFA) means fatty acids with one cis double bond and/or cis,cis-methylene interrupted double bonds

“Saturates” or “saturated fat” or “saturated fatty acids” (SAFA) means fatty acids without double bond

“Trans” or “trans fat” or “trans fatty acids” (TFA) means fatty acids with minimal one double bond that has been isomerized into trans

“Omega 3” or “omega 3 fatty acids” means fatty acids having the first double bond at the third carbon atom counting from the methyl end of the carbon chain (clarified at the Council of Experts, 24.9.2004)

“Cholesterol” is a member of the sterol family and is commonly present in the free or esterified form

ARTICLE 3 (labelling)
Margarine and fat spreads will be labelled in accordance with the general provisions of the Labelling Directive 2000/13 and the Nutrition Labelling Directive 90/496.
The precise wording of the nutrition claim is left to the individual company, as long as the criteria are met.

ARTICLE 4 (Community based nutrition claims)
Council Regulation (EC) No 2991/94 provides in Article 5.2 the following nutrition claims:
“The term “reduced fat” may be used for products referred to in the Annex with a fat content of more than 41% but not more than 62%
The terms “low fat” or “light” may be used for products referred to in the Annex with a fat content of 41% or less.”

ARTICLE 5 (General conditions)
The nutrition claims listed in Annex I will only be used for margarine and fat spreads which meet all of the following general criteria:

• a total fat content above 20% fat
• a minimum of 70% total fatty acids as cis UFA
• 0.6 mg _-tocopherol/g linoleic acid
• 0.9 mg _-tocopherol/g linolenic acid or VLCP N3

A nutrition claim listed in Annex I will only be used when the specific conditions for that claim are met.

ARTICLE 6 (modifications to the Code)
Any modifications to this Code of Practice shall require approval by the members of IMACE at the General Assembly.
The Code will be reviewed at least every 3 years.

ARTICLE 7 (entry into force)
This Code of Practice shall enter into force on 1 July 2003 at which date the previous Code (Dublin Agreement of 1992) will be repealed.

ANNEX I
Non-exhaustive list of nutrition claims and their specific conditions
as referred to in Article 5

Low content of SAFA
Maximum 25% of the fatty acids are derived from SAFA and TFA.*

Free of cholesterol
Maximum 5 mg cholesterol per 100 gram product

High content of PUFA
Minimum 45% of the fatty acids is derived from PUFA

High content of MUFA
Minimum 45% of the fatty acids are derived from MUFA

High content of UFA
Minimum 70% of the fatty acids are derived from UFA

High in Omega 3 (revised wording approved at AGM, 17.5.2004)
At least one of the following conditions is met**:

• Minimum 0, 6 g alpha-linolenic acid per 100 gram/100 ml product
• Minimum 60 mg very long chain Omega 3 per 100 gram/100 ml product

As long as minimum 30% of the dietary recommendation is met per average daily intake of the product

Source in Omega 3 (addition approved at AGM, 17.5.2004)
At least one of the following conditions is met**:

• Minimum 0, 3g alpha-linolenic acid per 100 gram/100 ml product
• Minimum 30mg very long chain Omega 3 per 100 gram/100 ml product

As long as minimum 15% of the dietary recommendation is met per average daily intake of the product

* In line with the IMACE Code of Practice on trans fatty acids it is recommended that all retail margarine/fat spreads contain a maximum of 1% TFA on a product basis.
** The type of Omega 3 eg. Alpha-linolenic acid and/or EPA and DHA should be labelled somewhere on the pack (clarified at the Council of Experts, 24.9.2004)

Code of Practice on Nutrition Claims (Update October 2004) [PDF]
Ann 1 - Monounsaturated Fat Rationale [PDF]
Ann 2 - Polyunsaturated Fat Rationale [PDF]
Ann 3 - Nutrition Claims in Margarine/Spreads (and other categories) [PDF]
Ann 4 - Unsaturated Fat Rationale [PDF]
Ann 5 - Omega 3 Claims Rationale [PDF]
Ann 6 - Free of cholesterol - Claims Rationale [PDF]