- Posted by: Dario Dongo
- Category: Questions and answers
Dear Dario good morning,
I found a Spanish non-alcoholic beer at Eataly, AMBAR 0,0% alc. vol., which is also presented as rich in fiber
(literally, "high in fiber"). The nutritional table refers to 0,8 g of fiber per 100 ml of beer. I am attaching the label.
What do you think about it?
The lawyer Dario Dongo, Ph.D. in European food law, answers
Dear Alessandro good morning,
First of all, it should be remembered that the labeling of non-alcoholic beer - like all non-alcoholic beverages, so qualified for an actual alcoholic strength by volume <1,2% (1) - follows the rules provided for by reg. EU 1169/11 for the generality of food products.
On this premise, the label proposed by you can be examined.
The Brewers of Europe - the confederation that represents 29 national federations of industrial and craft beer producers at EU level - distinguished itself favorably with respect to the European representatives of wine and alcoholic beverage producers.
The only brewers they have in fact adopted, on a voluntary basis, the practice of indicating both the list of ingredients and the nutritional declaration on the label. (2) Waiting for the European Commission to put an end to the shameful exemption so far granted to alcoholic beverages. (3)
AMBER non-alcoholic beer, ingredients list not compliant
The label non-alcoholic beer is in any case subject to mandatory indication of both of these items. The AMBER 0,0% actually shows a rather extensive list of ingredients, with some non-conformities:
- 'isomaltulose (source of glucose and fructose)’,
- 'dietary fiber ' of an unknown nature. In violation therefore of the reg. EU 1169/11, (4)
- 'natural flavors'. Note how the Spanish language label refers only to 'aromas'. Another, not negligible, element (5) to be clarified.
claim 'rich in fiber' nutritional
I nutrition and health claims affixed on a voluntary basis in commercial information relating to food products (e.g. labels and advertising online and e offline, social networks included) are governed by reg. CE 1924/06 and subsequent amendments.
I claim nutritional 'high fiber content''rich in fiber'and others of equal significance for the consumer are allowed - as provided in the Annex to reg. CE 1924/06 - only if the product contains at least 6 g of fibers per 100 g, or at least 3 g of fibers per 100 kcal. (6)
'Rich in fiber', verification of compliance
Verification of conformity of claim nutritional 'high in fiber'therefore requires a simple calculation. In the case of AMBER non-alcoholic beer, 0,8 g of fiber is at 19 kcal (per 100 ml) as x is at 100 kcal. That is to say that the drink offers (0,8 × 100) / 19 = 4,2 g of fiber per 100 kcal, a higher share with a reasonable margin compared to the requirement indicated by the reg. CE 1924/06. (7)
Non-alcoholic beer under examination appears interesting in the overall presentation, as well as in his halo health inspired by the high fiber content which complies with the rules in force. The indication 'gluten free', without giving up the use of a barley malt (cereal that contains gluten) is also interesting.
Sin slip right on the identity card of the label, the ingredients list. With two errors that moreover jump at a glance. In this regard, it is useful to remember that non-compliance with reg. EU 1169/11 - sanctioned in Italy by Legislative Decree 231/17 - integrate the administrative responsibility of the distributor, in addition to that of the trademark owner. (8)
(1) EU Reg. 1169/11, article 9.1.k
(2) The Brewers of Europe (2019). #BeerWisdom. Ingredients and Nutrition Labeling of Beer.
(3) Martha Strinati. Labeling of alcoholic beverages, work in progress in Brussels. GIFTS (Great Italian Food Trade). 5.10.21/XNUMX/XNUMX,
(4) Dario Dongo. Vegetable fibers and extracts, which ones? GIFTS (Great Italian Food Trade). 1.11.17/XNUMX/XNUMX,
(5) Natural flavors, the lawyer Dario Dongo replies. DO (Food and Agriculture Requirements). 16.10.18/XNUMX/XNUMX,
(6) Dario Dongo. ABC nutrition facts. GIFTS (Great Italian Food Trade). 26.5.18/XNUMX/XNUMX,
(7) It is always useful to remember the zero tolerance on the nutritional values covered by nutrition claim and health claims. See previous article 'Protein bars, 2 out of 3 contain less protein than claimed. Our investigation'
(8) Dario Dongo. The responsibilities of the large-scale retail trade. GIFTS (Great Italian Food Trade). two.