5. Claim Requirements

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General Foods
Pakistan

This section provides information on the definition of different types of claims and any restrictions or allowance of claims as well as claim registration processes.

5.1 Overview of Claims

5.1.1 Types & Definitions

1. DEFINITIONS [1] (as per Codex Alimentarius)

1.1 Nutrition claim means any representation which states, suggests, or implies that a food has particular nutritional properties including but not limited to the energy value and to the content of protein, fat, and carbohydrates, as well as the content of vitamins and minerals. The following do not constitute nutrition claims:

the mention of substances in the list of ingredients;
the mention of nutrients as a mandatory part of nutrition labeling;
quantitative or qualitative declaration of certain nutrients or ingredients on the label if required by national legislation.

1.1.1 Nutrient content claim is a nutrition claim that describes the level of a nutrient contained in a food (e.g. “source of calcium”; “high in fiber and low in fat”).

1.1.2 Nutrient comparative claim is a claim that compares the nutrient levels and/or energy value of two or more foods (e.g. “reduced”; “less than”; “fewer”; “increased”; “more than”).

1.1.3 Non-addition claim means any claim that an ingredient has not been added to a food, either directly or indirectly. The ingredient is one whose presence or addition is permitted in the food and which consumers would normally expect to find in the food.

1.2 Health claim means any representation that states, suggests, or implies that a relationship exists between a food or a constituent of that food and health. Health claims include the following:

1.2.1 Nutrient function claims – a nutrition claim that describes the physiological role of the nutrient in growth, development, and normal functions of the body. Example: “Nutrient A (naming a physiological role of nutrient A in the body in the maintenance of health and promotion of normal growth and development). Food X is a source of/ high in nutrient A.”

1.2.2 Other function claims – These claims concern specific beneficial effects of the consumption of foods or their constituents, in the context of the total diet on normal functions or biological activities of the body. Such claims relate to a positive contribution to health or to the improvement of a function or to modifying or preserving health. Example: “Substance A (naming the effect of substance A on improving or modifying a physiological function or biological activity associated with health). Food Y contains x grams of substance A.”

1.2.3 Reduction of disease risk claims – Claims relating the consumption of a food or food constituent, in the context of the total diet, to the reduced risk of developing a disease or health-related condition. Risk reduction means significantly altering a major risk factor(s) for a disease or health-related condition. Diseases have multiple risk factors and altering one of these risk factors may or may not have a beneficial effect. The presentation of risk reduction claims must ensure, for example, by use of appropriate language and reference to other risk factors, that consumers do not interpret them as prevention claims. Examples: “A healthful diet low in nutrient or substance A may reduce the risk of disease D. Food X is low in nutrient or substance A.”; “A healthful diet rich in nutrient or substance A may reduce the risk of disease D. Food X is high in nutrient or substance A.”

5.1.2 List of Prohibited Claims

As per Codex Alimentarius on the Guidelines on Claims [2] that Pakistan adopted, the following claims are prohibited:

Claims stating that any given food will provide an adequate source of all essential nutrients, except in the case of well-defined products for which a Codex standard regulates such claims as admissible claims or where appropriate authorities have accepted the product to be an adequate source of all essential nutrients.
Claims implying that a balanced diet or ordinary foods cannot supply adequate amounts of all nutrients.
Claims which cannot be substantiated.
Claims as to the suitability of a food for use in the prevention, alleviation, treatment, or cure of a disease, disorder, or particular physiological condition unless they are:
- in accordance with the provisions of Codex standards or guidelines for foods as developed by the Committee on Nutrition and Foods for Special Dietary Uses and follow the principles set forth in these guidelines.
Claims which could give rise to doubt about the safety of similar food or which could arouse or exploit fear in the consumer.

The following are examples of claims which may be misleading:

Meaningless claims including incomplete comparatives and superlatives.
Claims as to good hygienic practice, such as “wholesome”, “healthful”, and "sound”.

5.2 Nutritional Claims

5.2.1 Permitted Claims

As per Pakistan standard PS/CAC/GL-23-2021 [1], the only nutrition claims permitted shall be those relating to energy, protein, carbohydrate, and fat and components thereof, fiber, sodium, and vitamins and minerals for which Nutrient Reference Values (NRVs) have been laid down in the Pakistan standards adopting Codex Guidelines for Nutrition Labeling [3] where nutrient content, nutrient comparative and non-addition claims can be made.

Details of the conditions for such claims are illustrated in PS/CAC/GL-23-2021 [1].

5.2.2 Nutritional Claim Registration

N/A

5.3 Health Claims

As per Pakistan standard PS/CAC/GL-23-2021 [1], health claims should have a clear regulatory framework for qualifying and/or disqualifying conditions for eligibility to use the specific claim, including the ability of competent national authorities to prohibit claims made for foods that contain nutrients or constituents in amounts that increase the risk of disease or an adverse health-related condition. The health claim should not be made if it encourages or condones excessive consumption of any food or disparages good dietary practices.

If the claimed effect is attributed to a constituent of the food, there must be a validated method to quantify the food constituent that forms the basis of the claim.

The following information should appear on the label or labeling of the food bearing health claims:

A statement of the quantity of any nutrient or other constituent of the food that is the subject of the claim.
The target group, if appropriate.
How to use the food to obtain the claimed benefit and other lifestyle factors or other dietary sources, where appropriate.
If appropriate, advice to vulnerable groups on how to use the food and to groups, if any, who need to avoid the food.
Maximum safe intake of the food or constituent where necessary.
How the food or food constituent fits within the context of the total diet.
A statement on the importance of maintaining a healthy diet.

5.3.1 Permitted Claims

As per Pakistan standard PS/CAC/GL-23-2021 [1], the following conditions need to be met for health claims:

Health claims must be based on current relevant scientific substantiation and the level of proof must be sufficient to substantiate the type of claimed effect and the relationship to health as recognized by generally accepted scientific review of the data and the scientific substantiation should be reviewed as new knowledge becomes available. The health claim must consist of two parts:
1. Information on the physiological role of the nutrient or on an accepted diet-health relationship; followed by
2. Information on the composition of the product relevant to the physiological role of the nutrient or the accepted diet-health relationship unless the relationship is based on a whole food or foods whereby the research does not link to specific constituents of the food.
Any health claim must be accepted by or be acceptable to the competent authorities of the country where the product is sold.
The claimed benefit should arise from the consumption of a reasonable quantity of the food or food constituent in the context of a healthy diet.
If the claimed benefit is attributed to a constituent in the food, for which a Nutrient Reference value is established, the food in question should be:
1. a source of or high in the constituent in the case where increased consumption is recommended; or,
2. low in, reduced in, or free of the constituent in the case where reduced consumption is recommended. Where applicable, the conditions for nutrient content claims and comparative claims will be used to determine the levels for “high”, “low”, “reduced”, and “free”.
Only those essential nutrients for which a Nutrient Reference Value (NRV) has been established in the Pakistan Standard, PS/CXG 2-2021 adopting Codex Guidelines on Nutrition Labeling [3], should be the subject of a nutrient function claim.