5. Claim Requirements

Beers, RTDs, Whisky
Mongolia

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

Mongolia lacks comprehensive national regulations specifically governing the use of nutrition and health claims on food labels. However, MNS 6648:2016 states that health claims may be made on food labels if the following requirements are met: 

• The claim is based on scientific evidence and has been accepted and approved by the competent health authority. 
• The claim must not promote violations of good dietary practices or excessive consumption of any food [1]. 

Although Mongolia’s labeling standards include a reference to health claim approval, there is no formal procedure for doing so. In the absence of detailed national regulations, market practices suggest that Mongolia frequently references international standards, such as the Codex Alimentarius Guidelines (CXG 23-1997), to assess the credibility of nutrition and health claims. While CXG 23-1997 is not officially adopted as a binding policy, it serves as a critical reference point, demonstrating Mongolia’s alignment with global best practices in evaluating such claims. The content in sections 5.1.1 to 5.3 is analyzed based on the CXG 23-1997 and other relevant Codex Alimentarius Guideline. 

5.1.1 Types & Definitions

“Claim” means any representation that states, suggests, or implies that a food has particular qualities relating to its origin, nutritional properties, nature, processing, composition, or any other quality [2].

5.1.2 List of Prohibited Claims

General Food

There is no list of prohibited claims given by Mongolian regulations or standards. Referring to CXG 1-1979 General Guidelines on Claims [2], as a practice in Mongolia applying the guidelines of international organizations, prohibited claims may include the below.

Claims that should be 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, or 
  • In the absence of an applicable Codex standard or guideline, permitted under the laws of the country in which the food is distributed.
• Claims which could give rise to doubt about the safety of similar food or which could arouse or exploit fear in the consumer. 

Examples of claims that may be misleading: 

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

5.2 Nutritional Claims

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: 

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

Nutrition claims include the following types: 

• Nutrient content claim is a nutrition claim that describes the level of a nutrient contained in a food. (Examples: “source of calcium”; “high in fibre and low in fat”.) 
• Nutrient comparative claim is a claim that compares the nutrient levels and/or energy value of two or more foods. (Examples: “reduced”; “less than”; “fewer”; “increased”; “more than”.) 
• 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 [3].

5.2.1 Permitted Claims

General Food

The only nutrition claims permitted shall be those relating to energy, protein, carbohydrate, and fat and components thereof, fibre, sodium and vitamins and minerals for which Nutrient Reference Values (NRVs) have been laid down in the CXG 2-1985 Guidelines on Nutrition Labeling [4].

When making a nutrient content claim listed in Table 10 below or a synonymous claim, the specified conditions in this table below must be met. 

If a food is naturally low in or free of the nutrient referenced in the claim, the description should not directly precede the food's name. Instead, it should be phrased as “a low-[nutrient] food” or “a [nutrient]-free food.” This ensures clarity and prevents misleading labeling. 

Table 10. Table of conditions for nutrient content claims [3] 

Category

Alcohol

Same as General Food above. 

Product

1) Beer

Same as "Category" above.

2) Alcoholic ready-to-drink beverages (such as Chuhai) 

Same as "Category" above.

3) Whisky

Same as "Category" above.

5.2.2 Nutritional Claim Registration

There is no requirement for nutritional claim registration. 

5.3 Health Claims

A 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 [3]. Health claims include the following: 

• 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.” 
• 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. Examples: “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.” 
• 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 using 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.”

5.3.1 Permitted Claims

According to the Joint Order of the Minister of Food, Agriculture and Light Industry and the Minister of Health on labeling requirements for alcoholic beverages, it is prohibited to place health claims on the label of alcoholic beverages [5]. 

Information regarding this draft joint order is mentioned in Section 4.7 of this guidebook - Additional Notes on Labeling.

5.3.2 Health Claim Registration

There is no requirement for nutritional claim registration. 

5.4 Other Notes or Requirements for Claims

N/A.

5.5 References

1. MNS 6648:2016 Requirements for labeling of food containers and packages 

https://members.wto.org/crnattachments/2022/TBT/MNG/22_2973_00_x.pdf

https://estandard.gov.mn/website/masm/standards_details.aspx?code=1be13ed3-7896-4f99-b538-b858ccfec03b 

2. CXG 1-1979 General Guidelines on Claims 

https://www.fao.org/fao-who-codexalimentarius/sh-proxy/tr/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXG%2B1-1979%252FCXG_001e.pdf

3. CXG 23-1997 Guidelines for Use of Nutrition and Health Claims 

https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXG%2B23-1997%252FCXG_023e.pdf

4. CXG 2-1985 Guidelines on Nutrition Labeling  

https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXG%2B2-1985%252FCXG_002e.pdf

5. Draft - Annex Two to the Joint Order No. ... of the Minister of Food, Agriculture and Light Industry and the Minister of Health dated ..., ..., 2024

https://mofa.gov.mn/files/pdf-files/ktuhju0nud/6459eae578a6a4593d74d3f1.pdf