CSPI International
Center for Science in the Public Interest

Diet & Health/Food Labelling & AdvertisingFunctional FoodsFood Safety StandardsIACFOCodex Alimentarius CommissionWorld Trade OrganizationNAFTAGeneration ExcessSafe Food International

IACFO proposed amendment to the general standard for the labelling of prepackaged foods (CL 2003/18-FL - Part B)

(Quantitative Ingredient Declarations)

(At Step 3)

The International Association of Consumer Food Organizations (IACFO) urges the Codex Committee on Food Labeling (CCFL) to revise the current standard for quantitative ingredient declarations (QUID) in a manner that supports efforts by national authorities to provide consumers with information about processed foods that they can use to improve their health and protect their pocketbooks.

Promoting Consumer Health:

The Report of the Joint WHO/FAO Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases (hereinafter, Technical Report 916) published in April 2003 recognized that the diseases caused by poor diets are now responsible for a huge and growing burden of disability and premature death in both developing and developed countries, placing additional burdens on already strained national health budgets.

The report states:

During the past decade, rapid expansion in a number of relevant scientific fields…has helped to clarify the role of diet in preventing and controlling morbidity and premature mortality resulting from noncommunicable diseases (NCDs)…The Consultation provided an opportune moment for FAO and WHO to draw on the latest scientific evidence available and to update recommendations for action to governments, international agencies and concerned partners in the public and private sectors. The overall aim of these recommendations is to implement more effective and sustainable policies and strategies to deal with the increasing public health challenges related to diet and health. (at 1-2)

The WHO report specified several foods that are commonly used as ingredients in processed food products for which there is convincing or probable evidence of a causative or protective effect on risks for chronic diseases.

As such, IACFO submits that this body of evidence is sufficient to justify amending the Codex standard to authorize national authorities to establish (if they see fit according to national public health priorities) mandatory percentage ingredient disclosure requirements for any of the ingredients listed in the following table whenever present in multi-ingredient food products, regardless of whether a marketing claim is made concerning the amount present in the food. The food ingredients identified by Technical Report #916 include:

fruits, vegetables, whole grain cereals, non-starch polysaccharides (from whole grains, fruits and vegetables), legumes, free sugars, preserved and red meat, salt preserved foods; salt (as distinct from sodium), fish, fish oils, unsalted nuts (in moderation), hydrogenated oils, Chinese-style salted fish, water (as an indicator of energy density)

QUID for these components of processed foods is necessary because, as the WHO noted, it is the foods themselves, not the presence of specific nutrients in the foods, which may create the beneficial or detrimental effect on health. Thus, IACFO supports retaining and advancing sections 5.1.1. (f) and (g) of the proposed draft amendment which permits national authorities to require QUID for ingredients that may affect the health of consumers, with the proviso that such disclosures may be required even where those ingredients are not the subject of explicit marketing claims.

Preventing Consumer Deception:

IACFO believes that manufacturers should be obliged to disclose QUID whenever there is a foreseeable likelihood that consumers will be deceived about ingredient composition as a result of marketing claims or consumer expectations about ingredient composition.

The current EU QUID standard seeks to accomplish this objective by requiring that even where no marketing claims are made, QUID must be disclosed when consumer expectations regarding ingredient composition are evident. IACFO believes this approach must be reflected in the revised Codex standard by retaining and advancing sections: 5.1.1 (b), (c), and (d) of the proposed draft amendment.

Response to Criticisms of the Proposed Draft Amendment:

In the 31st session of CCFL, several unsubstantiated arguments were raised against expanding the ambit of the Codex QUID standard. These arguments were put forth almost exclusively by national authorities with little or no experience implementing QUID, and by food industry INGOs whose member companies already routinely comply with existing QUID laws in the European Union, Australia, New Zealand, and Thailand (and, in so doing, routinely overcome the barriers they continue to depict as insurmountable).

  1. Costs of Providing QUID

There is no evidence to indicate that providing QUID would pose a perceptible economic burden on industry or consumers. Little, if any, analytical work is necessary to determine appropriate QUID because such information is already possessed by the manufacturer. Rather than the direct costs of QUID, which are most certainly low, manufactures are more likely concerned about the impact that QUID may have in the marketplace. Consumers could be expected to switch brands or demand that products are made with, for instance, more vegetables or chicken and less refined flour or sugar if they have access to QUID. But costs associated with meeting demands created by the consumers’ informed choice should not be cited as barriers to policy change.

  1. Relevance of other nutrition information on labels

The fact that other existing Codex food labeling standards permit national authorities to require the provision of nutrition information is not relevant to ensuring that manufacturers provide QUID. Only percentage ingredient declarations can substantiate express or implied ingredient claims. For example, even in countries where full nutrition labeling is required, QUID is important because the amount of healthful ingredients cannot always be ascertained by reading the nutrition information panel. For example, nutrition labeling does not permit consumers to compare the whole grain content of various breads or crackers, the amount of vegetables in vegetarian lasagna, the amount of dried fruit in so-called "fruit bars," or the amount of added sugars in apple sauce.

  1. Intellectual property rights

As the European Food Law Association indicated in the 32nd session of CCFL, QUID does not present legal problems for food manufacturers. QUID information is now routinely yielded in more than 18 countries. QUID does not disclose production methods or manufacturing processes which might be subject to intellectual property protections in some cases. Nor does the QUID, as proposed, require disclosure of spices or seasonings that might be present in small amounts.

Finally, we request that the Secretariat solicit a legal opinion from the World Health Association’s Commission on Intellectual Property Rights, Innovation and Public Health (CIPIH) as to the scope of intellectual property rights concerning QUID for food. The CCFL has a responsibility to ensure that its standard-setting is guided by well-considered legal opinions by qualified experts, not unsubstantiated assertions of legal rights, particularly when those assertions are advanced by organizations whose members have vested commercial interests in the matter.

Food ingredients for which there is convincing or probable evidence of causative or protective effects on disease risks (Report of the Joint WHO/FAO Expert Consultation on Diet, Nutrition and the Prevention of Chronic Diseases, (Tech. Rpt. 916), Geneva, 2003)

Common processed food ingredients with non-nutrient health effects


Cardiovascular Disease



Dental Caries



X (96,100)

X (81,89,90)

X (86)

X (75,77)



X (96,100)

X (81,89,90)

X (86)

X (75, 77)


Whole grain cereals


X (88, 90)


X (75, 77)


Non-starch polysaccharides (from whole grains, fruits, vegetable)


X (82, 90)


X (75, 77)


X (58, 63)



X (89)

X (89)

X (77)


X (56 footnote "c")

Free sugars


X (109, 112, 114, 116, 118, 119)

X (57)

Preserved and red meat

X (96)


Salt preserved foods; salt (as distinct from sodium)

X (96)




X (81, 88, 90)


Fish Oils


X (81, 88)


Unsalted nuts (in moderation)


X (82, 87, 88)


Hydrogenated Oils


X (89)


Chinese-style salted fish

X (96)


Water (as an indicator of energy density)


X (70)

N.B. Numbers in parentheses refer to pages in Technical Report #916 where applicable conclusions are made.