4. Labeling Requirements

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4. Labeling Requirements

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General Foods
Pakistan

This section provides information on labeling requirements and the label approval process.

4.1 Mandatory Labeling Parameters

A. Prepackaged

The following particulars shall be marked or labeled on each container [1]:

Name and type of the product
Name and address of the manufacturer
List of ingredients in descending order
Country of Origin
Batch or code numbers,
Net weight in kilograms/gram
Date of manufacturer and expiry, and storage instructions
Pakistan Standard Number, PS: Mark, and license number
Declaration of allergen(s)
Instruction for Use
When sugars are fully or partly replaced by sweeteners, an appropriate declaration should be included in the proximity of the sales designation of the Cocoa product, mentioning the presence of sweeteners. Example: “X cocoa product with sweeteners”
The halal logo is mandatory for all imported prepackaged food products

NUTRIENT DECLARATION [2]

a) Application of the nutrient declaration

Nutrient declaration is mandatory for all prepackaged foods [2] for which nutrition or health claims, as defined in the Pakistan Standard, PS/CAC/GL-23-2021 adopting Codex Guidelines for Use of Nutrition and Health Claims (CAC/GL 23-1997) [3], are made.

The nutrient declaration is mandatory for all other prepackaged foods except where national circumstances would not support such declarations. Certain foods may be exempted, for example, on the basis of nutritional or dietary insignificance or small packaging.

b) Listing of nutrients

Where the nutrient declaration is applied, the declaration of the following should be mandatory:

Energy value
Protein
Available carbohydrates (i.e. dietary carbohydrates excluding dietary fiber)
Fat
Saturated fat
Sodium
Total sugars
Amount of any other nutrient for which a nutrition or health claim is made

c) Presentation of nutrient content

The declaration of nutrient content should be numerical. However, the use of additional means of presentation should not be excluded.

Information on energy value should be expressed in kJ and kcal per 100 g or per 100 ml or per package if the package contains only a single portion. In addition, this information may be given per serving as quantified on the label or per portion provided that the number of portions contained in the package is stated.

Information on the amounts of protein, carbohydrate, and fat in the food should be expressed in g per 100 g or per 100 ml or per package if the package contains only a single portion. In addition, this information may be given per serving as quantified on the label or per portion provided that the number of portions contained in the package is stated.

The presence of available carbohydrates (i.e. dietary carbohydrates excluding dietary fiber) should be declared on the label as “carbohydrates”. Where the type of carbohydrate is declared, this declaration should follow immediately the declaration of the total carbohydrate content in the following format:

Where the amount and/or type of fatty acids or the amount of cholesterol is declared, this declaration should follow immediately the declaration of the total fat in the following format:

Numerical information on vitamins and minerals should be expressed in metric units and/or as a percentage of the NRV per 100 g or per 100 ml or per package if the package contains only a single portion. In addition, this information may be given per serving as quantified on the label or per portion provided that the number of portions contained in the package is stated.

d) Tolerances and compliance

Tolerance limits should be set in relation to public health concerns, shelf-life, accuracy of analysis, processing variability, inherent liability and variability of the nutrient in the product, and, according to whether the nutrient has been added or is naturally occurring in the product.

The values used in nutrient declaration should be weighted average values derived from data specifically obtained from analyses of products that are representative of the product being labeled.

In those cases where a product is subject to a Codex standard, requirements for tolerances for nutrient declaration established by the standard should take precedence over these guidelines.

PRINCIPLES AND CRITERIA FOR LEGIBILITY OF NUTRITION LABELING [2]

General principles

In the case of nutrition labeling, whether applied on a mandatory or voluntary basis, the principles of Sections 8.1.1, 8.1.2, 8.1.3, and 8.2 of the Pakistan Standard, PS/CXS 1-2021 General Standard for the Labelling of Prepackaged Foods [1] should be applied.

Specific features of presentation

These recommendations relate to specific features of the presentation and are intended to enhance the legibility of nutrition labeling. However, competent authorities may determine any additional means of presentation of nutrition information taking into account approaches and practical issues at the national level and based on the needs of their consumers.

Format – Nutrient content should be declared in a numerical, tabular format. Where there is insufficient space for a tabular format, the nutrient declaration may be presented in a linear format. Nutrients should be declared in a specific order developed by competent authorities and should be consistent across food products.

Font – The font type, style, and minimum font size as well as the use of upper and lower case letters should be considered by competent authorities to ensure legibility of nutrition labeling.

Contrast – A significant contrast should be maintained between the text and background so that the nutrition information is clearly legible.

Numerical Presentation – The numerical presentation of nutrient content should be in accordance with the provisions stated in Section (c) under “NUTRIENT DECLARATION” above.

B. NOT prepackaged

The following must be displayed at the point of sale:

Name of Food
Production and Expiry Date

Note: This is an established practice as accepted and verbally recommended by Authorities to Bakery Sale Points in Pakistan.

4.2 Languages

Both English and Urdu.

4.3 Mandatory Information on Stickers

Stickers can only be used to reflect the same mandatory Information in Urdu on the stickers which must be otherwise imprinted on the Products Package. Under no circumstances the information shall be changed during translation into Urdu. The manufacturing and expiry date, nutritional/ingredient information, and Halal logo shall not be imprinted on stickers or pasted over.

4.4 Product Legal Name

The name shall indicate the true nature of the food and normally be specific and not generic [1]:
1. Where a name or names have been established for a food in a Codex standard, at least one of these names shall be used.
2. In other cases, the name prescribed by national legislation shall be used.
3. In the absence of any such name, either a common or usual name existing by common usage as an appropriate descriptive term that was not misleading or confusing to the consumer shall be used.
4. A “coined”, “fanciful”, “brand” name, or “trademark” may be used provided it accompanies one of the names provided in Subsections 1.1 to 1.3.
There shall appear on the label either in conjunction with, or in close proximity to, the name of the food, such additional words or phrases as necessary to avoid misleading or confusing the consumer in regard to the true nature and physical condition of the food including but not limited to the type of packing medium, style, and the condition or type of treatment it has undergone (e.g.: dried, concentrated, reconstituted, smoked).

4.5 Product-specific Labeling Statements

N/A

4.6 Authority Approval

As per the Decision of the National Standards Steering Committee in Pakistan held in February 2023 [4], it is mandatory to get the label approved by only one Provincial Authority, and the same shall be applicable and accepted by other Provincial Authorities. The best organized and online system for food label approval is from the Punjab Food Authority [5]. As other Authorities do not have well-organized and online approval of labels, they accept the label approvals done by the Punjab Food Authority. However, after the label approval from the Punjab Food Authority, PSQCA will charge a marking fee of 0.5% of the cost of the product as a Pakistan Standard Logo imprinting fee.

In light of the above, the approval process of the Punjab Food Authority is described below.

Application process:

The Food Business Operator (FBO) must register through the following website using his National CNIC Number and Pakistani Mobile Number: https://cell.pfa.gop.pk/register?go_to=product_label_application.
After Registration, the FBO will receive a code through a text message.
With this Code, the FBO will be able to register on the online portal, fill out the form, and upload the label as well as the Certificate of Analysis and Halal or other Claim Certificate on the portal and pay the application fee generated through the system.
If the label is found compliant, then the Label approval is received within 4 weeks.
If the label is non-compliant, then the team of the Authority will inform the Applicant online of the required rectifications or will call him for in-person guidance and once the amended and compliant label is submitted by the applicant then final approval is received in 4 weeks.

4.7 Additional Notes on Labeling

Presentation of mandatory particulars [1]

The name of the Food, the Description, and the Net Contents shall be placed on the front of the label.
The Manufacturing and Expiry dates shall be mentioned in a clear and conspicuous place; on top at the package or bottom of the package.
Nutritional Table, Allergen warning, Ingredients, Name and Address of Manufacturer, Importer, etc. shall be written on the back of the label.

Irradiated foods [1]

The label of a food that has been treated with ionizing radiation shall carry a written statement indicating that treatment in close proximity to the name of the food. The use of the international food irradiation symbol, as shown below, is optional, but when it is used, it shall be in close proximity to the name of the food.

When an irradiated product is used as an ingredient in another food, this shall be so declared in the list of ingredients.

When a single-ingredient product is prepared from a raw material that has been irradiated, the label of the product shall contain a statement indicating the treatment.

GMO labeling

If the product claims to be GMO-free, then the GMO-free certification must be available as per practice that claims need to be substantiated with evidence.

Voluntary information

Social Media Logos, etc. can be used.

Labeling of Organic food

If a food claims to be organic, organic food certification is required as per practice that claims need to be substantiated with evidence.

Labeling relating to recycling

There is no legislation on recycling. A recycling logo can be used.

Labeling of Halal, Kosher, Vegan.

Halal Certification and logo are mandatory for all prepackaged food products that are required to be registered with the food Authorities and their labels are required to be approved prior to their placement on the market [6]. However, for non-prepackaged food products, a Halal Certificate and Logo are not required as these are not prepackaged products even though all food products need to be halal.

There is no legislation on Kosher and Vegan labeling.