Nutrition and Health Claims on an EU Online Food Shop

“High protein”, “source of fibre”, “no added sugar”, “supports your immune system”. These phrases sell food online, and in the EU each one is regulated. You may only use a nutrition claim that is on the EU’s list, and only if your product meets its conditions. You may only use a health claim that has been authorised.

This guide covers the rules, the conditions for the claims food shops use most, and the common mistakes. It builds on our guides to the EU nutrition declaration format and EU allergen information for online food shops.

This is general information, not legal advice. For a specific product, check with your national food authority or a food law adviser.

The rules in one place

The law is Regulation (EC) No 1924/2006 on nutrition and health claims made on foods. The quotes below come from the consolidated version of 13 December 2014 on EUR-Lex.

Article 1(2) says it applies to claims “made in commercial communications, whether in the labelling, presentation or advertising of foods to be delivered as such to the final consumer”. That wording is broad. Treat your product titles, descriptions, images, badges, ads and marketing emails as covered, not only the printed pack.

The Regulation defines three kinds of claim (Article 2(2)):

Type	What it does	Example
Claim	Any message or representation that is not mandatory, “including pictorial, graphic or symbolic representation”, which states, suggests or implies that a food has particular characteristics	A “protein” badge on a product image
Nutrition claim	Says the food has beneficial nutritional properties because of the energy or the nutrients it provides, provides in reduced or increased amounts, or does not contain	“Low fat”, “high fibre”
Health claim	Says or implies “that a relationship exists between a food category, a food or one of its constituents and health”	“Calcium is needed for the maintenance of normal bones”

Note “pictorial”: an icon next to a protein figure can be a claim without words.

General rules for every claim

Article 3 says a nutrition or health claim must not:

1. be false, ambiguous or misleading
2. raise doubt about the safety or nutritional adequacy of other foods
3. encourage or condone excess consumption of a food
4. state, suggest or imply that a balanced and varied diet cannot provide appropriate quantities of nutrients in general
5. refer to changes in bodily functions that could give rise to or exploit fear in the consumer

Article 4 adds a special rule for alcohol: drinks with more than 1.2% alcohol by volume may not bear health claims, and only a few nutrition claims about low or reduced alcohol or reduced energy.

Nutrition claims: only from the Annex

Article 8(1) is short: “Nutrition claims shall only be permitted if they are listed in the Annex and are in conformity with the conditions set out in this Regulation.” The Annex also covers “any claim likely to have the same meaning for the consumer”. Writing “packed with protein” instead of “high protein” does not avoid the condition.

Here are the conditions for the claims online food shops use most, from the Annex:

Claim	Condition
Low energy	No more than 40 kcal (170 kJ)/100 g for solids or 20 kcal (80 kJ)/100 ml for liquids
Energy-reduced	Energy value reduced by at least 30%, stating what makes it reduced
Low fat	No more than 3 g fat/100 g for solids or 1.5 g/100 ml for liquids (1.8 g/100 ml for semi-skimmed milk)
Fat-free	No more than 0.5 g fat/100 g or 100 ml. Claims like “X% fat-free” are prohibited
Low saturated fat	Saturated plus trans fat no more than 1.5 g/100 g (solids) or 0.75 g/100 ml (liquids), and no more than 10% of energy
Low sugars	No more than 5 g sugars/100 g for solids or 2.5 g/100 ml for liquids
Sugars-free	No more than 0.5 g sugars/100 g or 100 ml
With no added sugars	No added mono- or disaccharides or other food used for its sweetening properties. If sugars occur naturally, add “contains naturally occurring sugars”
Low sodium/salt	No more than 0.12 g sodium (or the equivalent salt) per 100 g or 100 ml
Source of fibre	At least 3 g fibre/100 g or 1.5 g fibre/100 kcal
High fibre	At least 6 g fibre/100 g or 3 g fibre/100 kcal
Source of protein	At least 12% of the energy value comes from protein
High protein	At least 20% of the energy value comes from protein
Source of [vitamin/mineral]	At least a “significant amount” as defined in EU law
High [vitamin/mineral]	At least twice the “source of” value
Reduced [nutrient]	At least 30% less than a similar product (micronutrients: a 10% difference in reference values; sodium/salt: 25%)
Light/lite	Same conditions as “reduced”, plus a statement of what makes it light
Naturally/natural	Only as a prefix, when the food meets the condition naturally

The Annex has more entries, such as “sodium-free”, “energy-free”, “increased [nutrient]” and omega-3 claims. Read it in full before using any of them.

Protein claims are about energy, not grams

Protein conditions are easy to misread. “High protein” does not mean “20 g of protein per 100 g”. It means protein supplies at least 20% of the food’s energy.

A worked example, using the energy factor of 4 kcal per gram of protein from Annex XIV of Regulation (EU) No 1169/2011:

1. A snack bar has 450 kcal and 20 g protein per 100 g.
2. Protein energy: 20 × 4 = 80 kcal.
3. Share of energy: 80 ÷ 450 = 17.8%.
4. That is above 12% but below 20%. The bar may say “source of protein”, not “high protein”.

A bar with 380 kcal and 20 g protein gives 80 ÷ 380 = 21.1%, which meets “high protein”. Same protein, different claim, because the energy changed.

Fibre, by contrast, has two routes: per 100 g or per 100 kcal. A low-energy food can be a “source of fibre” per 100 kcal with less than 3 g per 100 g.

A claim brings the nutrition declaration with it

Article 7 makes nutrition labelling mandatory for any product that bears a nutrition or health claim, except in generic advertising. If the claim concerns a substance that is not in the nutrition declaration, its amount must be stated “in the same field of vision” as the nutrition labelling.

So a “high fibre” badge needs fibre in your nutrition table, even though fibre is otherwise optional. Our nutrition declaration guide explains the table format.

Comparative claims

Saying your granola has “30% less sugar” is a comparative claim. Article 9 says a comparison may only be made between foods of the same category, considering a range of foods in that category. You must state the difference in the nutrient or energy, and compare the same quantity of food. If you claim a reduction, the Annex’s “reduced” condition also applies: at least 30% less for most nutrients.

Health claims: only from the EU list

Article 10(1) says health claims are prohibited unless they are authorised and included in the lists of authorised claims. The general list is Commission Regulation (EU) No 432/2012, which has been amended since. The EU Register of nutrition and health claims is the Commission’s reference to the current position. It lists authorised claims with their conditions of use, and non-authorised claims with the reasons.

Each authorised claim comes with conditions. Three examples from Regulation 432/2012:

Claim	Condition of use
“Protein contributes to a growth in muscle mass”	Food is at least a source of protein as defined in the Annex
“Vitamin C contributes to the normal function of the immune system”	Food is at least a source of vitamin C
“Wheat bran fibre contributes to an acceleration of intestinal transit”	Food is high in that fibre; consumers must be told the effect is obtained with a daily intake of at least 10 g of wheat bran fibre

So a health claim usually depends on a nutrition claim condition first, and the wording is part of the authorisation.

What must go with a health claim

Article 10(2) says a health claim is only permitted if the labelling, or where there is none the presentation and advertising, includes:

1. a statement on the importance of a varied and balanced diet and a healthy lifestyle
2. the quantity of the food and pattern of consumption needed to get the claimed effect
3. where appropriate, a statement for people who should avoid the food
4. a warning for products likely to present a health risk if consumed to excess

General wellbeing claims

Phrases like “good for you” or “supports wellbeing” refer to general, non-specific benefits. Article 10(3) allows them only if accompanied by a specific authorised health claim.

Banned outright

Article 12 does not allow health claims that:

• suggest health could be affected by not eating the food
• refer to the rate or amount of weight loss
• refer to recommendations of individual doctors or health professionals, other than the associations mentioned in Article 11

Botanicals and pending claims

The Register’s page explains that some claims are not listed because their assessment is unfinished, including claims on botanical substances. Absence from the list is not a green light. If your product is a herbal food or supplement, ask your national authority how such claims are treated.

Common mistakes on product pages

• “High protein” based on grams per 100 g. The condition is 20% of energy.
• “95% fat-free”. The Annex prohibits claims expressed as “X% fat-free”.
• “No added sugar” on a fruit product without the extra statement. If sugars occur naturally, add “contains naturally occurring sugars”.
• A claim with no nutrition table, or a fibre claim without fibre in it. See Article 7.
• Strengthening an authorised health claim. “Boosts immunity” is not the authorised wording for vitamin C.
• Vague benefit wording on its own, such as “good for you”, without a specific authorised claim.
• Weight-loss figures. “Lose 2 kg a week” is banned.
• Forgetting images and badges. Pictorial representations count as claims.

A checklist before you publish a claim

1. Find the exact claim, or the closest one with the same meaning, in the Annex or the EU Register.
2. Check your product’s nutrition values against the condition. For protein, calculate the share of energy.
3. Make sure the nutrient in the claim appears in your nutrition declaration.
4. For a health claim, use the authorised wording and meet its conditions of use.
5. Add the information Article 10(2) requires next to a health claim.
6. Keep a record of the values and the source you checked, so you can show it if asked.

FAQ

Can I write “high protein” if my product has 20 g protein per 100 g?

Only if protein provides at least 20% of the product’s energy. Multiply the protein grams by 4 kcal and divide by the total kcal. A product with 20 g protein and more than 400 kcal per 100 g qualifies only as a “source of protein”.

Where do I find the list of authorised health claims?

In the EU Register of nutrition and health claims. It lists authorised claims with their conditions and non-authorised claims with the reasons. The Commission presents the Register as information only; the legal acts are what bind.

Do the claim rules apply to my product page or only to the pack?

Article 1(2) covers claims in labelling, presentation and advertising of foods delivered to the final consumer. Treat your product page, ads and emails as covered.

Where EU Food Labels fits

StoreFleet: EU Food Labels shows the mandatory information from Regulation (EU) 1169/2011 on your product pages: the nutrition table (including optional fibre), ingredients, emphasised allergens and food business operator details. It does not check, suggest or display nutrition or health claims. You still need to confirm each claim against the Annex and the EU Register yourself. See also why nutrition and allergen metafields don’t show.