Compulsory nutrition declaration, starting on 14.12.16. The ABC of the rules to be applied

As of 14 December 2016, almost all food products (1) must be packaged with labels bearing a specific nutritional declaration, as established in Regulation (EU) 1169/11. Below is a summary of the rules to be applied.

Field of application. The table must be affixed on the labeling of prepacked foods intended for sale to the final consumer only (to which communities are equivalent). If the products are intended for the so-called B2B sale, the information must in any case be provided, albeit through documents that accompany or precede the delivery of the goods.

The nutrition declaration on the other hand, it is not required on pre-wrapped products, nor on the sale signs of bulk products, nor on the registers and menus of public establishments.

Nutritional values, sources. The values ​​to be declared are "average values" which can be extracted, alternatively, from:

- laboratory analysis (on significant aliquots of different samples) of the food (2),
- calculation "made from average values ​​(known or actual) relating to the ingredients used",
- calculation made from "generally established and accepted" data 3.

Please note that the calculation carried out starting from the ingredients, it can be distorted by the changes in the nutrients that result from the manufacturing process (eg leavening, cooking, seasoning).

The use of the so-called bibliography, in turn, it is not possible in relation to compound foods that present particular variations according to the recipe used by each operator (eg filled pasta, baked goods, margarines, snacks and snacks, ice cream).

It is still necessary keep records of the analyzes and / or calculations carried out, including the technical data sheets of the suppliers.

Nutritional declaration. The mandatory nutrition declaration must include, in order: energy (kJ, kcal), fats, of which saturated fatty acids, carbohydrates, of which sugars, proteins, salt. This last value must be understood as "sodium-equivalent", ie it corresponds to the total sodium content (from any source) contained in the product, multiplied by 2,5. The fibers, which in any case contribute to the calculation of energy (at the rate of 2 kcal / g), can be inserted in the table before the proteins (4).

On a "relatively" voluntary basis - since it is mandatory if a "claimNutritional on some of the relative elements - monounsaturated and polyunsaturated fats (after the saturated fats), polyols (5) and starch (after sugars) can be added in order.

They can also be added, where present in significant quantities (6), in the list after salt, vitamins and minerals. The latter must be declared both in absolute value and as a percentage of the nutritional reference values ​​(7).

Roundings and tolerances. The European Commission has defined in specific guidelines the rounding criteria and the tolerances on the values ​​to be displayed in the nutritional declaration (8), the application of which varies according to the nutrient and its quantities.

When any of the values ​​are lower than the defined limits, which vary according to the individual nutrients, (9) it is possible to indicate "0" or "0,5" (fats, carbohydrates, sugars, polyols, starch, fibers, proteins), "0" or "< 0,1 "(saturated, monounsaturated and polyunsaturated fatty acids)," 0 "or" <0,01 "(undetectable salt or <0,0125) .10

Figures are shown in units when higher than 10, with only one decimal if lower than 10 (but higher than 0,5 for fats, carbohydrates, sugars, polyols, starch, fibers, proteins, and higher than 0,1 for saturated, monounsaturated and polyunsaturated fats). For salt, if greater than 1 only one decimal is used, if less than 1 two decimal places.

The energy it must always be expressed with whole numbers and its value is not subject to tolerances since its calculation must be made on the basis of the declared nutrients, following the relative rounding (11).

Vitamins and minerals, depending on the case, they must sometimes be indicated with three significant figures (vitamin A, folic acid, chlorine, calcium, phosphorus, magnesium, iodine and potassium), at least two significant figures for the other micronutrients.

Expression per 100g / ml and per serving. The nutritional declaration must always refer to 100 grams or milliliters of product. On a voluntary basis, the values ​​relating to the portion, clearly identified by weight or volume, can be added. If it refers to the portion, it is also mandatory to indicate the number of portions contained in the package (with a wording such as “contains X portions”).

Dario Dongo


1 Without prejudice to those listed in Annex V to regulation (EU) 1169/11

2 To optimize costs, a single analysis can be performed on the mixture of multiple samples that come from different production batches (eg "sample made up of a pool of 3 different batches")

3 These data must be extracted from authoritative sources, eg. food composition tables elaborated by CREA, formerly INRAN, on

4 It is suggested to insert the fiber content in the table, whenever they are present, both to facilitate the verification of the congruence of the energy value, and to inform the consumer about a favorable and useful data for composing a balanced diet.

5 Remember that polyols have a conversion coefficient equal to 2,4 kcal / g, and their value must be subtracted from that of carbohydrates for the exact calculation of the energy value. Also in this case, where polyols are present, it is recommended to insert them in the table to allow the verification of the congruity of the declared energy.

6 Pursuant to reg. UE 1169/11, Annex XIII, Part A

7 Idem cs

8 CE Guidelines, DG Sanco, December 2012

9 Cf. Guidelines Min. Ps. 16.6.2016 on the analytical tolerances applicable in the official control phase

10 NB: when the test report indicates values ​​lower than the detection limits of the analytical method, the value is in fact zero

11 NB: the conversion coefficients established for each nutrient in Annex XIV of reg. UE 1169/11 must be applied separately, for kJ and kcal, for the purpose of calculating the energy value. Consequently, it is forbidden to calculate the energy in kJ by converting the value of the kcal

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