Comparative nutrition claims

Comparative nutrition claims are claims that compare the composition of the food in question with another food. Comparative nutrition claims are addressed in Article 9 of the Claims Regulation which states that a comparison may only be made between foods of the same category, taking into consideration a range of foods of that category.

The difference in the quantity of a nutrient and/or the energy value shall be stated and the comparison shall relate to the same quantity of food. The composition shall be compared with a range of foods of the same category, which do not have a composition which allows them to bear a claim, including foods of other brands.

The only comparative nutrition claims permitted in the Annex to the Regulation are

  • "increased [name of the nutrient]"
  • "reduced [name of the nutrient]"
  • "energy-reduced"
  • "light/lite"

The Guidance published by the Commission on 14 December 2007 on the implementation of the Claims Regulation provides more detailed guidance for the use of comparative claims. According to it, comparative claims are always nutrition claims and a comparative claim shall always indicate the difference in the quantity of a nutrient or the energy value.

Comparison is only permitted based on the nutritional content between foods of the same category. This means that comparison between e.g. milk and butter is not possible.

For a comparison, a range of foods of the same category shall be taken into account, taking several foods of the same category into consideration, including also foods of other brands in the market area where the product is to be marketed. The requirement for comparison of a range of products is designed to prevent situations where comparison to a single product will mislead the consumer, in case the reference product is not a representative example of the food category. The larger the range of comparable products on the market, the larger the range of products considered in the comparison shall be to ensure that the range of products is adequately large and representative. If the selection available on the market changes frequently, the comparison shall be updated on a regular basis, at intervals of ca. 2 years.

Page last updated 11/9/2018