Annex E
The draft advice, issued last month, updates guidance the FSA produced in 2008 and is open for comment and consultation until the 23rd March.
As well as updating the role of charities and national associations, the 146-page guidance has a section on recommendations by doctors and health professionals.
Much of the updated draft was drawn from meetings with UK stakeholders and member states, as well as developments that have become apparent as the regulation has been implemented.
In regard to endorsements, the FSA notes the regulation stipulates that national rules should apply, although no such rules exist in the UK. Therefore it advised that any endorsement that implied a health claim must be included on the authorised list that is being built under the regulation.
“If the recommendation or endorsement implies a reference to general, non-specific benefits of a food for overall good health then, in accordance with Article 10(3), it would need to be supported by a relevant, authorised health claim,” suggests the guidance.
“In some cases, the recommendation or endorsement may be a trademark, for example a charity logo. If so, and the trademark would be construed as a nutrition or health claim, it must comply with Article 1(3) and be accompanied by a relevant, authorised nutrition or health claim.”
“You must be clear if such a partnership is purely for fundraising purposes as consumer research shows that consumers often infer health benefits from products associated with the name of a health-related national association or charity.”
Other updates include advice on vitamin and mineral claims; beauty claims; a new section on the use of ‘reduced energy’ and ‘reduced alcohol’ claims on alcoholic beverages; information on the article 13 health claim authorisation process and information on foods for children.
Information about the draft guidance can be found here.