Guidelines for Highlighted Ingredients and Flavours
Annex 2 - Application of the Guidelines Examples
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These guidelines are under review while marked as Archived Content. See Highlighted Ingredient Claims for the current policy.
Note: The lists of ingredients provided in this annex contain only the ingredients relevant to the discussion and thus are not necessarily complete.
- Chocolate Chip Cookie
- Cereal Bars
- Pizza
- Cereal
- Seafood Mix
- Honey Spread
- Snacks
- Juice and fruit drinks
- Butter Pastry
- Cookies
- Graham Crackers
- Candy Bar
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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1.1 Label: "Chocolate Chip Cookie" Ingredients: 6% carob chips and 5% chocolate chips |
Not acceptable as an imitation ingredient is also present without additional information. Some clarifying options would be to indicate the percentage of chocolate chip on the principle display panel or to include similar ingredients in the common name:
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1.2 Label: "Cookie" with the claim "made with chocolate chips" Ingredients: 6% carob chips and 5% chocolate chips |
Similar to the previous example, the real chocolate chips are highlighted through the claim but imitation ingredients are present. The options are similar to Example 1.1:
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1.3 Label: "Cookie" plus an additional image of a chocolate slab Ingredients: 6% carob chips and 5% chocolate chips |
Similar to the previous example, the real chocolate chips are highlighted through the image of the chocolate slab but an imitation ingredient is present. The options similar are Example 1:
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1.4 Label: "Cookie" plus an additional vignette of the cookie showing chips Ingredients: 6% carob chips and 5% chocolate chips |
Acceptable. The label does not highlight real chocolate chips. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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2.1 Label: "Cereal Bar" and "Raspberry Flavour flash The red fruit composite particles are visible in either the product (transparent package) or the vignette of the product, at time of sale. Ingredients: 8% fruit composite (consisting of cranberries, fillers and raspberry flavour) |
Not acceptable as an imitation ingredient is also present without additional information. Raspberry has been highlighted by the flavour statement and the erroneous impression given is that the visible red pieces are raspberries in the product. Some clarifying options would be to indicate the percentage of strawberries on the principle display panel or to specifically disclose all similar ingredients:
Indicating "flavour" is not an option here, as it is the flavour statement that contributed to the improper highlighting. Note that if the red fruit composite were not visible in the product or on the vignette at the time of sale, it would then be acceptable as the consumer would not be lead to believe that real raspberries are present in the food. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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3.1 Label: "Pepperoni Pizza" With pepperoni slices visible in either the product or the vignette. Ingredients: The slices are simulated pepperoni made from textured soy protein |
Not acceptable as an imitation ingredient is present without additional information to disclose the real nature of the slices. Consumers would expect real pepperoni slices. Some clarifying options are:
Simply adding "0% Pepperoni" or "contains no pepperoni" would contradict the label as a whole and confuse/mislead consumers. |
3.2 Label: "Pepperoni Pizza" With the slices visible in either the product or the vignette. Ingredients: 5% pepperoni (real pepperoni) |
Acceptable. In this case there are no similar ingredients present. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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4.1 Label: "Soy Cereal" with a label showing only soy Ingredients: 40% soy, 25% wheat, 20% oats, and 5% rice |
Not acceptable; even though soy is more prominent than each similar ingredient, the total weight of all highlighted and similar ingredients represents the majority of the food and the label does not somehow indicate that similar ingredients are present. Options could include indicating the percentage of soy, or indicating that soy is added for flavour.
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4.2 Label: "Soy Cereal" Ingredients: 40% wheat, 25% soy, 20% oats, and 5% rice. |
Not acceptable as the name does not indicate other similar ingredients are present. As all similar ingredients represent together the majority of the food and the soy part of the product is not present in a higher amount than each similar ingredients, some options are:
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Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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5.1 Label: "Seafood mix with Crab" With a vignette of a crab Ingredients: 40% Cod, 40% Pollack and 10% crab |
Not acceptable: crab is highlighted by both the vignette and the common name and the highlighted and similar ingredients together represent the majority of the food. Because crab is not present in a higher amount than each similar ingredient, some clarifying options would be:
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5.2 Label: "Seafood and Crab Mix"
Ingredients: 40% Cod, 40% Pollack and 10% imitation crab" |
Not acceptable as an imitation ingredient is also present without additional information. Crab has been highlighted in the name, the imitation crab is visible, and there is a vignette of a crab. The erroneous impression given is that real crab is contained in this seafood product. Some clarifying options would be:
Simply adding "0% Crab" or "contains no crab" would contradict the label as a whole and confuse/mislead consumers. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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6.1 Label: "Honey Spread" with vignettes of bees, hives and honey dippers Ingredients: 46% corn syrup and 44% honey |
Not acceptable. As all similar ingredients represent together the majority of the food and the highlighted ingredient is not the most prominent, the similar ingredients should be identified by common name, or use a percentage/flavour statement.
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Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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7.1 Label: "Fruit Snack" or "Fruit flavoured snack - made with real oranges" Ingredients: 70% (sugar, flavour, pectin, starch) and 24% concentrated orange puree |
Not acceptable: even though oranges are present, the name does not indicate other similar ingredients (sugar/flavour/pectin) are present in a higher amount. Some clarifying options would be:
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7.2 Label: "Fruit flavoured gummy treats" or "gummy and fruit flavoured snacks - made with oranges" or "fruit flavoured snack - made with real oranges in a candy" Ingredients: 70% (sugar, flavour, pectin, starch) and 24% concentrated orange puree |
Acceptable: These common names are acceptable as they make it clear this is not solely a fruit product but is a candy-like product made with fruit or fruit flavouring. Note: If other fruits had been present, the "orange fruit" highlighting would be further evaluated against the amount of the other fruit ingredients. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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8.1 Label: "Cranberry Drink"; or "Fruit Drink" plus a large CRANBERRY, and with a cranberry vignette Ingredients: 60% water, 20% apple juice, and 10% cranberry juice |
Acceptable: see Annex 1, section 8c. With no mention or representation of "juice" simple common names such as "cranberry drink" are accepted as indicating "cranberry flavoured drink". Note: This would apply whether cranberry juice, other fruit juices, or no juice of any kind is actually present in the product. |
8.2 Label: "Blueberry Juice Drink" Ingredients: water, glucose, blueberry juice (5%), flavour |
Not acceptable; "Juice" may not be in the common name of a drink unless there is at least 25% total juice (and the percentage is declared). See Annex 1, section 8a. Options include:
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8.3 Label: "Cranberry and Mixed Berry Juice Blend" with vignettes of cranberry, blueberry and strawberry Ingredients: Concentrated apple (50%), cranberry (20%), blueberry (15%) and strawberry juices (15%) |
Not acceptable as non-berry juice (apple) is also present but not represented. (Also, cranberry should not be shown first within the common name as it is not the most prominent juice in the blend). Some clarifying options would be:
Note: See Annex 1, section 8a as percentage juice statements are required whenever "juice" is in the common name. |
8.4 Label: "100% Juice Blend"; Plus "cranberry" and the image of cranberries Ingredients: Water, Concentrated Grape, Cranberry and Apple Juices |
Not acceptable. Cranberry is highlighted and there is no indication that "blend" refers to other juices. Some clarifying options would be:
Note: See Annex 1, section 8a as percentage juice statements are required whenever "juice" is in the common name. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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9.1 Label: "Butter Cake" or "Made with butter" Ingredients: 5% butter and 8% canola oil |
Not acceptable as butter and canola oil represent less than the majority of the food and butter is not the most prominent. Some clarifying options would be:
Note: The label would be acceptable if the ingredients had been 7% butter and 6% canola oil. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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10.1 Label: "Butter oatmeal cookies with a creamy filling" Ingredients: 8% butter and 5% canola oil Note: the filling contains hydrogenated palm oil. |
Acceptable; the butter claim relates solely to the biscuit portion of the product, which is distinct from the filling. As the butter and canola oil represent less than the majority of the food, and that butter is more prominent, there is no objection to the label. |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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11.1 Label: "Honey Graham Crackers" Ingredients: 10% graham flour, 5% sugar, 3% honey, sodium bicarbonate |
Graham highlighting is acceptable as white flour is not counted towards the weight of similar ingredients. See Exception for Bakery Products in Annex 1, section 4. Honey highlighting is acceptable as honey is present in a dry product with no other similar ingredient present to simulate its flavour (See Annex 1, section 6 Generally recognized as flavour statement). |
Product Label and Advertising Information and Formulation | Acceptability and Possible options (not exhaustive) |
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12.1 Label: "Maple" and a maple leaf vignette. Common name is "candy bar" Ingredients: chocolate, sugar,... natural maple flavour |
Not acceptable. The claim "Maple" and the maple leaf vignette highlights maple as an ingredient. Since no real maple is present, there should be clarifying information to indicate that fact;
Note that either option would have to be prominently displayed. |
12.2 Label: "Maple" and a maple leaf vignette. Common name is "candy bar". Ingredients: chocolate, [...], 38% maple syrup, 1.2% natural maple flavour |
Acceptable. The wording "Maple" and the maple leaf vignette highlights maple as an ingredient. As real maple is present with a very small amount of flavour, this is not misleading to consumers. |
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