Energy - Nutrition Labelling
	Updated 2019-11-03

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Energy calculations for nutritionl labelling

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Under construction

The following sections contain a description of the international standards/guidelines and regulations for nutrition labelling with special emphasis on the energy calculation procedures, definitions of food components and the use of energy conversion factors.

Energy calculations are described in the guidelines and regulations as follows
 

• Codex Alimentarius Commission’s Guidelines for Nutrition Labelling (CAC/GL 2-1985, revised 2013)
   
• European Council Directive 90/496/EC of 24 September 1990 on nutrition labelling for foodstuffs and amendments
   
• US Public Law 101-535 Nutrition Labeling and Education Act of 1990 (NLEA)
   

There are conceptual differences in the guidelines/regulations. Some of these are described below.

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The interpretations and implementations of the standards and regulations for nutrition labelling

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Both the Codex Alimentarius Guidelines and the EC Directive on nutrition labelling are subject to somewhat lacking definitions and thus open for individual and national interpretations.

Although the Codex Alimentarius Guidelines and the EC Directive on nutrition labelling are very similar, there are important differences. Most important is the difference in the definition of carbohydrate, which in the case of the Codex Alimentarius Guidelines is called available carbohydrate and defined as

• carbohydrate excluding dietary fibre (and available carbohydrate should be referred to as carbohydrate)

and in the EC Directive carbohydrate is

• any carbohydrate which is metabolised in man, and includes polyols

Neither of these definitions give any hint on how to determine carbohydrate.
Only the U.S. NLEA gives a clear definition of carbohyrate as

• calculated by subtraction of the sum of the crude protein, total fat, moisture, and ash from the total weight of the food

i.e. carbohydrate is determined by difference.

Furthermore, the dietary fibre definition of the Codex Alimentarius Guidelines and EC Directive seem to being both defined by a functional property in the human digestive tract and indirectly by a method of analysis. This may inevitably lead to some contradictions in the definition of the actual food components.

In addition, and maybe more important, the dietary fibre definition includes carbohydrate components not digested in the small intestine, but are components that reach the large intestine and are fermented by the colonic microflora with the production of, among other substances, short chain fatty acids, which are available as energy yielding components. It concerns components like cellulose, hemicellulose, pectins, etc.

The carbohydrate definition in the EC Directive is more general and covers more components, but which to some extent - like the definition of the Codex Alimentarius Guidelines ‘carbohydrate’ - lacks definition for direct measurement. Both the Codex Alimentarius Guidelines and the EC Directive are unclarified concerning the method for measurement of dietary fibre: ‘as determined by the agreed upon method, or fibre: ‘by the method of analysis to be determined’, respectively.

Unclear definitions together with national/local legislation might lead to different, sometimes doubtful interpretations concerning the component(s) carbohydrate. The definition of carbohydrate in the Codex Alimentarius Guidelines implies some sort of ‘a difference’ with the exclusion of ‘dietary fibre’ from a ‘carbohydrate’.

This has led to the dubious interpretation that ‘available carbohydrate in general can be defined by mixing the definition from the Atwater system with the newer knowledge about the physiological ‘unavailability’ of some ‘unavailable’ carbohydrates:

• ‘available carbohydrate’ = total carbohydrate (by difference) – dietary fibre

and using unchanged energy conversion factors for the ‘available carbohydrate’.

This interpretation is seen in many national food composition tables. The concept is a little doubtful, because in the Atwater system the ‘indigestibility’ of the dietary fibre is actually included in the energy conversion factors. Hence, the correction for ‘indigestibility’ of dietary fibre is done twice, and the estimation of the food’s energy content may be underreported. It can of course be discussed how much fibre there was in the American diet, the Atwater energy factors were determined on. Furthermore, dietary fibre has an energy value, which has now been acknowledged in the Codex Alimentarius Guidelines and the EC Directive on Nutrition Labelling. This was thoroughly pointed out in the FAO publication, Carbohydrates in Human Nutrition.

A slightly different interpretation of this definition is found the Nutrition Labeling and Education Act (NLEA) of 1990 where carbohrate for energy calculation purposes may be counted as

• total carbohydrate less the amount of insoluble dietary fiber

The definition of dietary fibre by method rather that by component(s) also leads to differences, as the different methods yields to different results. There are presently three methods for dietary fibre, which have been officially approved by bodies such as AOAC International (Association of Official Chemists) and the Bureau Communitaire de Référence (BCR) of the European Community:

• the enzymatic, gravimetric AOAC of Prosky and co-workers, and subsequently Lee and co-workers
   
• the enzymatic-chemical methods of Englyst and co-workers
   
• the enzymatic-chemical method of Theander and co-workers (the Uppsala method)
   

Due to the somewhat open interpretation of the dietary fibre definition, it has been necessary further to describe applicable methods in guidance documents. For example, the various methods for analysing fibre are set out in the European Commission’s Guidance document on Methods of Analysis for Determination of the Fibre Content declared on a Label (December 2012).
Guidance notes are also published bu national authorities, for example the Swedish Food Administration.

On the more general level, FAO maintains a list of Guidance notes from contries around the world, Guidance for Industry (FAO).
 

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References

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• Codex Alimentarius Commission:
  Codex Guidelines for Nutritional Labelling. CAC/GL 2 – 1985 (Adopted 1985. Revisions 1993 and 2011. Amendment 2003, 2006, 2009, 2010, 2012 and 2013. Annex adopted 2011 and revised 2013).
  Joint FAO/WHO Food Standards Programme, FAO, Rome 2013.
   
• Codex Alimentarius Commission: Codex Committee on Nutrition and Foods for Special Dietary Uses. Twenty-second Session, Berlin, Germany, 19-23 June 2000. Discussion Paper on Energy Conversion Factors (Prepared by Australia), CX/NFSDU 00/11, Joint FAO/WHO Food Standards Programme, FAO, Rome, March 2000.
   
• Joint FAO/WHO Expert Consultation on Carbohydrates in Human Nutrition:
  Carbohydrates in human nutrition.
  FAO Food and Nutrition Paper - 66.
  FAO, Rome, 1998.
   
• Carbohydrates in human nutrition.
  Report of a Joint FAO/WHO Expert Consultation, Rome, 14-18 April 1997.
  FAP Food and Nutrition Paper 66.
  FAO, Rome, 1998.
   
• The Council of the European Communities:
  Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling for foodstuffs.
   
• Commission Directive 2003/120/EC of 5 December 2003 amending Directive 90/496/EEC on nutrition labelling for foodstuffs.
   
• Commission Directive 2008/100/EC of 28 October 2008 amending Council Directive 90/496/EEC on nutrition labelling for foodstuffs as regards recommended daily allowances, energy conversion factors and definitions.
   
• Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004.
   
• European Commission, Health and Consumers Directorate-General:
  Guidance document for competent authorities for the control of compliance with EU legislation on:
  Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004 and Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling of foodstuffs and Directive 2002/46/EC of the European Parliament and of the Council of 10 June 2002 on the approximation of the laws of the Member States relating to food supplements
  with regard to the setting of tolerances for nutrient values declared on a label.
   
• European Commission, Health and Consumers Directorate-General:
  Guidance document for competent authorities for the control of compliance with EU legislation on:
  Council Directive 90/496/EEC of 24 September 1990 on nutrition labelling of foodstuffs and Regulation (EU) No 1169/2011 of the European Parliament and of the Council of 25 October 2011 on the provision of food information to consumers, amending Regulations (EC) No 1924/2006 and (EC) No 1925/2006 of the European Parliament and of the Council, and repealing Commission Directive 87/250/EEC, Council Directive 90/496/EEC, Commission Directive 1999/10/EC, Directive 2000/13/EC of the European Parliament and of the Council, Commission Directives 2002/67/EC and 2008/5/EC and Commission Regulation (EC) No 608/2004
  with regard to methods of analysis for determination of the fibre content declared on a label.
   
• Public Law 101-535 - Nutrition Labeling and Education Act of 1990.
   
• U.S. Code of Federal Regulations, 21 CFR 101.9 Nutrition labelling of foods.
   
• U.S. Food and Drug Administration:
  Nutritional Labeling and Education Act (NLEA) Requirements (8/94 - 2/95)
   
• U.S. Food and Drug Administration:
  Guide to nutrition labeling and Education Act (NLEA) Requirements - Attachment 6-8
   
• U.S. Food and Drug Administration:
  Labeling & Nutrition Guidance Documents & Regulatory Information Guidance for Industry
   
• U.S. Food and Drug Administration:
  Food Labeling Guide (revised January 2013)
   
• Food energy - methods of analysis and conversion factors.
  Report of a technical workshop, Rome, 3-6 December 2002.
  FAO Food and Nutrition Paper 77
  FAO, Rome, 2003.
   
• Merrill, A.L. and Watt, B.K.:
  Energy Value of Foods … basis and derivation.
  Agriculture Handbook No. 74, revised February 1973.
  Human Nutrition Research Branch, Agricultural Research Service, United States Department of Agriculture. 
   
• Statens Livsmedelsverk:
  Statens livsmedelsverks kungörelse med föreskrifter och allmänna råd om näringsvärdedeklaration. SLV FS 1993:21, Statens Livsmedelverk, Uppsala, December 1993, recent amendment 30 september 2009,  SLV LIVSFS 2009:9 .
   
• Statens Næringsmiddeltilsyn:
  Forskrift om deklarasjon av næringsinnhold. 21.12.1993 nr. 1386.
  Statens Næringsmiddeltilsyn, Oslo, December 1993.
   
• Food and Agriculture Organization of the United Nations:
  Food Labelling - Guidance for industry

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