As many readers will be aware the consultation is now open on the setting of nutrient profiles under European Regulation (EC) No 1924/2006.
The Food Standards Agency (FSA) has requested feedback on the EuropeanCommission working document on the setting of nutrient profiles. The working document is a slightly confusing read as it is peppered with explanation of how the suggested profile has been tested, but the guts of what you need to read are held in pages eight and nine. Though you can cross your fingers and pray your products are listed in the exemptions on pages three and four, I doubt it.
Page nine provides a table setting threshold values for sodium, saturates and sugars which will determine the ability of your food to carry nutrition and/or health claims. If your product exceeds any of the threshold levels, goodbye health claims and restrictions kick in for nutrition claims. Fail two and your choices narrow further.
Some food categories have different threshold values and the test to see if you are in a particular category is by looking at the eligibility criteria on page eight.
To see the typical impact of the profile on a range of foods the test results from the work by the Commission and European Food Safety Authority are provided in an accompanying spreadsheet. If your product is out of profile but similar ones are in then the chance of persuading the Commission to change its criteria is going to be pretty slim.
I would urge you to consider the impact on your products which havea health positioning and put forward through the FSA any nutrition based rationale you can present to argue for amended thresholds/special category status.
Sadly the results indicate that a Christmas pudding is not likely to be able to carry heath claims, though probably a slice could make a portion of your five-a-day claim!
Have a great Christmas!