Nutrient Content Claims

When a product bears a nutrient content claim (whether it is expressed or implied), certain information must be incorporated into the design of the package. Because many claims appear on the PDP, this panel usually is affected. When a claim appears elsewhere on a package, however, certain information must appear on the panel with the claim.

Required Statement. Depending on the type of claim and whether the product is governed by FDA or USDA, the requirements for claims-related information vary. FDA mandates more extensive information than USDA (ie, the inclusion of either a referral or a disclosure statement). Both agencies require additional information on products bearing comparative claims.

Claims on FDA Products. All FDA products bearing nutrient content claims require either a referral or a disclosure statement to be included on each panel where a claim appears, except the nutrition facts panel. A referral statement, appearing next to the largest claim on each panel, directs the consumer to the nutrition facts statement. When a product contains excessive levels of key nutrients that are associated with health risks, the referral statement is replaced with a disclosure statement that flags the nutrient(s) of concern and directs the consumer to the nutrition facts panel.

Comparative Claims. Both FDA and USDA product labels that bear a comparative claim must include a nutrient claim clarification statement and quantitative information. On FDA products, this information is required in addition to a referral or a disclosure statement.

The nutrient claim clarification statement identifies the comparison food and states the percentage (or fractional) difference in the subject nutrient(s) between the product and its comparison food (eg, 50% less fat than [comparison food], 1/3 fewer calories than [comparison food]).

The quantitative information provides the absolute amounts of the subject nutrient(s) in the product and in the comparison food.

Design Elements. USDA and FDA differ slightly in their design requirements for claims-related information. USDA

does not require referral or disclosure statements; FDA applies the type-size standards defined for these statements to other claims-related statements.

Claims Statements. Claims may not have undue prominence because of type style in comparison to the product identity statement. A claim may be no longer than two times the size of the product identity.

Referral or Disclosure Statement. On FDA products, a referral or a disclosure statement must be immediately adjacent to the claim. No intervening material may be placed between it and the claim, except for other claims-related statements, or a standard name that is modified by the claim, or both. It must appear on each panel where the claim is located, except for the panel that contains the nutrition facts (eg, if the nutrition facts and the claim are both on the PDP, the statement is not required). If multiple claims appear on a panel, the referral or disclosure statement must be adjacent to the largest claim.

It must be in easily legible, boldface type, in distinct contrast to other printed or graphic matter. It may be no smaller than the net quantity declaration, unless the claim is less than two times the size of the net quantity declaration.

Nutrient Claim Clarification Statement. The nutrient claim clarification statement must be placed in immediate proximity to the most prominent comparative claim. It must follow the same type-size requirements as the referral statement. If different comparative claims appear on the same label, the nutrient claim clarification statement must be placed in immediate proximity to the most prominent presentation of each claim.

Quantitative Information. Clear and concise quantitative information must appear adjacent to the most prominent claim or on the Information Panel.

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