the food and drink innovation network omega-3 seminar, northamptonshire, 19 th oct 2005
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DESCRIPTIONHealthy Claims. The Food And Drink Innovation Network Omega-3 Seminar, Northamptonshire, 19 th Oct 2005 Melanie Ruffell, Executive Director UK Joint Health Claims Initiative Food Industry Enforcement Consumers. Overview. JHCI background General principles for making healthy claims - PowerPoint PPT Presentation
The Food And Drink Innovation NetworkOmega-3 Seminar, Northamptonshire, 19th Oct 2005
Melanie Ruffell, Executive DirectorUK Joint Health Claims Initiative
General principles for making healthy claims
Substantiation requirements overview
JHCI approved claim for LC omega-3 PUFA
A unique joint venture between consumer organisations, enforcement authorities and industry trade associations
To establish a voluntary Code of Practice for the use of health claims on food, beverages and supplements
To provide case by case advice and an independent scientific opinion about the validity of health claims
To help ensure claims do not mislead consumers or contravene food law
What is the JHCI?
Who is the JHCICouncil - 3 Enforcement authority reps - 3 Food industry reps - 3 Consumer interest reps - Independent Chairman
Secretariat - Executive Director - Administration Assistant
Expert Committee- 7 independent scientists
Observers- FSA, ITC, CAP/ASA, BACC
to protect and promote public health
to help companies to provide accurate & responsible information relating to food to enable consumers to make informed choices
to promote fair trade & innovation in the food industry
to promote consistency in the use of health claims across different media
to promote consistency in the regulation of health claims in the UK, Europe and internationally.
How JHCI can help The Code is not part of food legislation and does not replace or compete with the current UK systems of regulation and self-regulation
IN THE SHORT TERM: Compliance with the Code assists companies to establish a defence of all due diligence in the event of prosecution over the truthfulness of claims
IN THE LONG TERM: Lack of high profile cases helps restore consumer faith in products carrying health claimsHelp prepare for the new legal environment and help ensure suitable claims stay on the market under new legislation
Types of claimsLc n-3 PUFA helps maintain a healthy heart(health maintenance) LC n-3 PUFA improves vascular endothelial function(enhanced function) LC n-3 PUFA contributes to normal vascular endothelial function(nutrient function)LC n-3 PUFA helps reduce the risk of CVD (disease risk reduction)MEDICINEFOOD LC n-3 PUFA helps prevent heart attacks(medicinal) Borderline Area
Implied claimsBrand namePicturesImagesEndorsementNB: Has not been considered by JHCI
Consumer perceptionConsumer perception is paramount
Not just one interpretation, but all likely interpretations of a health claim must comply with the Code
A range of factors which can determine consumer perception, e.g. use of pictures and logos on the packagingHOW WILL THE CONSUMER INTERPRET THE STATED OR IMPLIED CLAIM?
Legal and Nutrition PrinciplesClaims should, e.g.:
not exaggerate the effect or claim benefits beyond the scope of evidence
be communicated in a way to assist consumer understanding of the basis of the health claim
include quantification of the active ingredient
be supported by instructions for recommended consumption patterns and amounts
Using pre-approved generic claimsClaims freely available from JHCI website
Approval includes claim-specific conditions for use and points to note
Companies strongly advised to discuss use of claims with JHCI to ensure products and marketing complies with the JHCI Code
Working with the Evidence:Substantiation of Health Claims
Approval process requirementsDossier must include:
Proposed health claimSystematic Review of EvidenceSupplementary information:Relevance to UK public health contextPotential implicationsTypical products likely to carry the claimSample labelsStatement of intended use; level and frequency of consumptionOther documentation (see JHCI Code)
Approved claims based on systematic review of evidenceWhat is a systematic review of the evidence?
Evidence directly linked to the claimSearched, reviewed and presented in an objective and unbiased mannerUsing a pre-defined and reproducible methodology.
Reassures the JHCI Expert Committee that all relevant papers have been included, so it can make an informed decision based on the totality of evidence.
Filtering the Evidence
FULL ARTICLES RETRIEVED
INCLUDED AS EVIDENCE
Statistical summary of data (forest plot)Demonstrates overall consistency of results
Dossier requirements put simply Unbiased, transparent systematic approach Evidence reflects application Set in (UK) public health context Anticipated use of claims Complies with legal and nutrition principles in Code
LC n-3 PUFA JHCI ClaimEating 3g weekly, or 0.45g daily, long chain omega-3 polyunsaturated fatty acids, as part of a healthy lifestyle, helps maintain heart health. (11/02/05) POINTS TO NOTE: A.The claim relates only to very long chain polyunsaturated fatty acids (of chain length 20 carbons or above) including EPA, DPA and DHA (i.e. 20:3n-3, 20:4n-3, 20:5n-3, 22:5n-3 and 22:6n-3), and not all long chain polyunsaturated fatty acids, such as alpha-linolenic acid (i.e. 18:3n-3 and 18:4n-3). The ratio of EPA and DHA should reflect that which occurs naturally in oily fish.
LC n-3 PUFA JHCI ClaimInclude the statement: The Government advises that at least 2 servings of fish, one of which should be oily, containing approximately 3g LC n-3 PUFA, is consumed each week. For fortified foods and supplements, inform consumers that oil-rich fish is an alternative source of LC n-3 PUFA. When a product is presented as a stand alone serving, then each serving must contain no less than 0.2g LC n-3 PUFA. Not personalise the claim to the individual, e.g. provides half your daily needs. B. Products carrying the claim should:
LC n-3 PUFA JHCI ClaimB. Products carrying the claim should (contd):When a product carries a recommendation for a number of portions per day or week then:
the total LC n-3 PUFA content of the daily recommendation (daily serving) must be greater than 0.2g.
the total LC n-3 PUFA content of the weekly recommendation (weekly serving) must be greater than 0.5g. 6.State the proportion (i.e. a quarter, third, half etc) of the 0.45g daily intake, or 3g weekly intake, in each serving or portion.
LC n-3 PUFA JHCI Claim7. Clarify the distinction between servings of a product and portions of oily fish. 8.Clarify to consumers when products have been fortified with LC n-3 PUFA and make clear to consumers the origin of the oil. 9.Products containing significant amounts of contaminants (identified by the SACN/COT Inter-Committee Subgroup to be marlin, swordfish, shark and, to a lesser extent, tuna) carrying the claim should also carry a warning for pregnant women and children. B. Products carrying the claim should (contd):
LC n-3 PUFA JHCI ClaimPOINTS TO NOTE (contd):
C.The JHCI Code states that health claims that could encourage high levels of consumption must not be made for any substances where there is evidence that high intakes of the food or substance could be harmful or unlikely to contribute to a healthy diet (refer section 6.2.16).
JHCI advises that products carrying the claim should make a positive contribution to healthy eating. Products high in saturated fatty acids, salt, sugar etc should therefore not be promoted on this basis.
LC n-3 PUFA JHCI ClaimPOINTS TO NOTE (contd):
D.The JHCI strongly recommends that companies seek advice from the Secretariat before using this claim to help ensure that the food product is consistent with good nutrition principles and complies with the JHCI Code of Practice for Health Claims on Food.
E.The wording of the claim has been carefully formulated to reflect the evidence on which the claim has been approved. Wording may be altered, in consultation with the JHCI, as long as the claim does not imply health benefits beyond the scope of the evidence change the meaning of the claim; or, confuse consumers.
LC n-3 PUFA JHCI ClaimApproval of the use of nutrient content claims on food labels is beyond the remit of JHCI, therefore appropriate legal advice must be sought by those wishing to use such claims.
However, the JHCI Expert Committee considered, from a scientific basis, that nutrient content claims could be substantiated as follows and recommended that it be made clear to consumers when these claims were in relation to the daily amount or weekly amount. NUTRIENT CONTENT CLAIMS
LC n-3 PUFA JHCI ClaimBased on a WEEKLY intake amount:A good source of the weekly intake = at least 1/6th of 3g LC n-3 PUFA per week A rich source of the weekly intake = at least of 3g LC n-3 PUFA per week Based on a DAILY intake amount:A rich source of the daily intake = at least of 0.45g LC n-3 PUFA per day Quantification of nutrient content claims should be reported to the nearest 0.1g/100g, so not to imply a higher level of precision than exists. NUTRIENT CONTENT CLAIMS (contd)
Dont dilute the claim ensure all salient points are included in any revised wordings.
The claim is about long chain n-3 PUFA this should not abbreviated to omega-3.
Ensure nutrition composition panel also is expressed in g not mg (to be consistent with claim).
LC n-3 PUFA JHCI ClaimGeneral advice:
JHCI Contact DetailsP.O. Box 43Leatherhead, SurreyKT22 7ZWUnited Kingdom
Ph: 0044 (0)1372 822 378Fax: 0044 (0)1372 822 288
- Overview of latest developments in Brussels.- The pros and cons of the proposed new Regulation.- Key issues for interested parties.- How the JHCI (Joint Health Claims Initiative) is working to help ensurethat the Regulation will be workable in practice.
Consistent reporting in the majority of source documents of relevant functions.
3) Well-establishedConsistent reporting in the majority of source documents of relevant functions (as agreed in Step 1)
Nutrient functionA claim that describes the physiological role of the nutrient in growth, development and normal functions of the body (Codex Guidelines for the Use of Nutrition Claims, CAC/GL 23-1997).
Health statementA statement related to a health benefit, or the avoidance of a health detriment(adapted from JHCI Code of Practice, 2000)
4) US Institute of Medicine - Dietary reference intakes for vitamins and minerals (1997 2001). Encyclopedia of Human Nutrition 2E (c1999)Reports of the European Scientific Committee on Food (1992 - 2003). Draft Reports of the UK Expert Group on Vitamins and Minerals (2002). Handbook of Nutrition and Food (2002). Reports of the UK Committee on Medical Aspects of Food and Nutrition Policy (1991 2000). Introduction to Human Nutrition (2002). Reports of the British Nutrition Foundation Task Force (1989 1995). International Life Sciences Institute (Europe) Concise Monograph Series (1999).
5) Nutrient X is necessary for / contributes to the normal growth / development / function of Y or Z
6) Table 1a: Well-established Nutrient Function Statements (Common to all Vitamins and Minerals)
Table 1b: Well-established Nutrient Function Statements (Specific to Certain Vitamins and Minerals)
Table 2: Rejected Nutrient Function Statements
Mg6 = straightforwardNi1 = does not mean boost to energyVB6 = meaningful to consumers? Contributes because folate and B12 tooFo2 = implied prevention claim?VC1 =implied treatment claim?Na1 = too contentious for health claim on food?