Getting Your Claims Right

Compliance template – nutrition content claims

Page last updated: 21 October 2014

This template may help food businesses build a nutrition content claim; and demonstrate due diligence in attempting to comply with the Food Standards Code.

See sections 2 and 3 of this document for the conditions for making nutrition content claims.

General information

1. What is the wording of your proposed nutrition content claim?

2. What food will you be applying the nutrition content claim to?

3. Has the form of the food to which the claim relates been determined in accordance with the Table to clause 6 of Standard 1.2.7?

Yes No

If NO, the claim is NOT permitted.

4. Does the nutrition content claim state the form of the food to which the claim applies together with the claim as required by clause 10 of Standard 1.2.7 unless the form of the food is as sold?

Yes No

If NO, the claim is NOT permitted in its current form.

5. Do words in the nutrition content claim refer to the prevention, diagnosis, cure, or alleviation of a disease, disorder or condition or compare a food with a good that is represented in any way to be for therapeutic use or likely to be taken to be for therapeutic use, whether because of the way in which the good is presented or for any other reason?

Yes No

If YES, the claim is NOT permitted.

6. Do any words used in the nutrition content claim alter or contradict the effect of a statement or information required by Standard 1.2.7?

Yes No

If YES, the claim is NOT permitted.

7. Do the details of the nutrient or biologically active substance used to make the nutrition content claim appear in the nutrition information panel (NIP) on the label of the package of the food as required by clause 5 of Standard 1.2.8?

Yes No

If NO, the particulars of the nutrient or biologically active substance MUST BE declared in the NIP, or if no label is required under subclause 2(1) of Standard 1.2.1, the NIP (with the particulars of the claimed nutrient or biologically active substance) should be displayed on or in connection with the display of the food or provided to the purchaser on request. This requirement does not apply to food in small packages; however certain information must be included on the label of the small package (clauses 8 and 8A of Standard 1.2.8).

8. What property of food (e.g. a vitamin, fat, energy or beta glucan) will the nutrition content claim be about?

9. Is the property of food listed in Column 1 of Schedule 1 of Standard 1.2.7?

Yes No

If NO, proceed to question 19.

10. Does the food and claim meet the applicable conditions in Column 2 (if any) for the property of food in Column 1 identified above, and if a descriptor or synonym of a descriptor in Column 3 is used in the claim, does the food and claim meet the applicable conditions in Column 4?

Yes No

If YES, go to question 11. If NO, claim is NOT permitted.

11. Demonstrate, as appropriate, how the nutrition content claim complies with all relevant conditions from Schedule 1 of Standard 1.2.7 (e.g. amount of substance in food, testing results).

If the claim is not about gluten, glycaemic index, glycaemic load or trans fatty acids, proceed to question 24 (comparative claims).

Specific substances: gluten, lactose, glycaemic index, glycaemic load or trans fatty acids

12. Is your nutrition content claim made about lactose or trans fatty acids?

Yes No

If NO, proceed to question 15.

13. If yes, what descriptors (if any) are applied?

14. Are the descriptors derived from Column 3 of Schedule 1 corresponding to the appropriate substance, or are they synonyms of those descriptors provided in Column 3 of Schedule 1?

Yes No

If NO, the claim is NOT permitted.
If YES, proceed to question 24.

15. Is your nutrition content claim about gluten?

Yes No

If NO, proceed to question 17.

16. If yes, are descriptors from Column 3 of Schedule 1 relating to gluten or synonyms of those descriptors used, or does your claim state that the food contains gluten or is high in gluten?

Yes No

If NO, the claim is NOT permitted.
If YES, you have finished.

17. Is your nutrition content claim about:

a) glycaemic index?

Yes No

If NO, proceed to question 19.
If YES, proceed to question 19 AND complete questions 33 and 34.

b) glycaemic load?

Yes No

If NO, proceed to question 19.
If YES, proceed to question 18 AND complete questions 33 and 34.

18. Does the nutrition content claim use a descriptor other than a number or a descriptor expressed in numeric form?

Yes No

If YES, the claim is NOT permitted.

19. Is a nutrition content claim made about folic acid, choline or fluoride?

Yes No

If NO, proceed to question 21.

20. If yes, does the food also carry a health claim about folic acid, choline or fluoride (as applicable, as referred to in the nutrition content claim)?

Yes No

If NO, nutrition content claim MAY NOT be made about that food.

If YES, you have finished. The nutrition content CLAIM MAY ONLY BE MADE about presence of folic acid, choline or fluoride or the amount of folic acid, choline or fluoride in a specified amount of the food. No descriptors in Column 3 of Schedule 1 (or any other descriptor) may be used for nutrition content claims made about folic acid, choline or fluoride.

If your claim is in Schedule 1, go to question 24 (comparative claims)

21. Is a nutrition content claim made about a property of food not mentioned in Schedule 1?

Yes No

If NO, proceed to question 24.

22. If yes, does the claim use a descriptor listed in Column 3 of Schedule 1 or any other descriptor except for a descriptor that indicates the food does not contain the property of food?

Yes No

If YES, the claim is NOT permitted. If NO, proceed to question 23.

23. Does the claim refer to the presence or absence of that substance, the specific amount of that property of food in a specified amount of the food or a descriptor that indicates the food does not contain the property of food?

Yes No

If NO, the claim is NOT permitted.
If YES, you have finished.

Specific conditions for nutrition content claims: comparative claims

24. Does the nutrition content claim compare the nutrition content of one food with another or is the word ‘diet’ used in a nutrition content claim?

Yes No

If NO, you do not need to address any further questions.

25. If yes, are the descriptors, ‘light’ or ‘lite’, ‘increased’, or ‘reduced’ used in the nutrition content claim?

Yes No

If yes, which of these terms is used?

26. If the above words are not used, but the nutrition content claim compares the nutrition content of one food with another, what words are used to describe the comparison between the claimed food and the reference food?

27. Does the comparative claim state the identity of the reference food and the difference between the amount of the relevant property in the claimed food and reference food?

Yes No

If NO, the claim is NOT permitted.

28. Does the claim directly or indirectly compare the vitamin or mineral content of a food with that of another food?

Yes No

If YES, the claim is NOT permitted unless the claim is permitted by another Standard in the Food Standards Code.

29. Is the word ‘diet’ used in a nutrition content claim?

Yes No

If YES, proceed to question 30 AND address questions 33 and 34.
If NO, you have finished.

30. If yes, is the ‘diet’ claim a comparative claim, i.e. does the food meet the conditions for making the ‘diet’ claim by having at least 40% less energy than the same quantity of reference food?

Yes No

If NO, proceed to question 32.

31. If yes, is the identity of the reference food and the difference between the energy content in the reference food compared to the claimed food provided together with the claim?

Yes No

If NO, the claim is NOT permitted.

32. For claims using the word ‘diet’ as a descriptor (i.e. claims that comply with the conditions for use of the ‘diet’ descriptor), are other descriptors used that directly or indirectly refer to ‘slimming’ or synonyms of slimming used?

Yes No

If YES, the claim is NOT permitted.

Questions 33 and 34 apply only if you are making a glycaemic index, glycaemic load or diet claim

33. What category does the food belong to in the Nutrient Profiling Scoring Criterion (NPSC) as listed in the ‘Category’ column of Schedule 4 of Standard 1.2.7?

Category 1 Category 2 Category 3

34. What is the final nutrient profiling score of the food in its specific category,
as listed in the ‘NPSC category’ column of Schedule 4 of Standard 1.2.7?

For information on calculating the nutrient profiling score see the FSANZ website.

If food is Category 1, nutrient profiling score must be less than 1 to qualify for the claim.

If food is Category 2, nutrient profiling score must be less than 4 to qualify for the claim.

If food is Category 3, nutrient profiling score must be less than 28 to qualify for the claim.

If the food does not meet the NPSC the glycaemic index, glycaemic load or diet claim is NOT permitted.