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Claims and wording

How a health claim gets authorised, and why most marketing phrases are not claims

Nutrition and health claims sit inside a closed authorisation system. Most front-of-pack wording sits outside it, which changes what it can be held to.

Claims10 min read
The short answer

A health claim on a food, meaning any statement that links the food or one of its constituents to health, may only be made if it appears on the authorised register and only in a form that carries the same meaning as the authorised wording. Nutrition claims are similarly limited to a defined list with conditions attached. The great majority of front-of-pack wording is neither, which is why it is not on any register: it is not making a claim the system recognises, and is instead governed only by the general prohibition on misleading consumers.

A closed list, not an open one

The regime governing nutrition and health claims on foods works by permission rather than prohibition. A claim of either kind is not allowed unless it has been specifically authorised. That is unusual in consumer law, which more commonly bans defined behaviours and leaves everything else open.

The consequence is that when a pack carries a genuine health claim, that claim has been through an assessment and appears on a public register. Great Britain maintains its own register of authorised nutrition and health claims, published by the government, and it is the definitive place to check.

Nutrition claims work slightly differently. Rather than an application process for each one, there is a defined list of permitted claims with conditions attached to each. A product may describe itself as low in a nutrient, or as a source of one, only where the specified thresholds are met and only using a form of wording with the same meaning as the permitted one.

Three categories worth separating

Nutrition claims state or imply that a food has particular beneficial nutritional properties because of what it contains or does not contain. Descriptions of a food being low in, high in, reduced in, free of, or a source of a nutrient are all nutrition claims, and each has conditions.

Health claims state or imply a relationship between a food or a constituent of it and health. These divide further. Function claims describe a role in growth, development or the functions of the body. Other categories cover reduction of disease risk and claims relating to children's development and health, and these are subject to a distinct and more demanding route.

General non-specific claims about a benefit to overall good health or health-related wellbeing may only be made if they are accompanied by a specific authorised health claim. This is the rule that governs the vague wellness phrasing on the front of many packs. The vague phrase is permitted only when a specific, authorised, checkable claim is attached to it.

Four kinds of wording and what governs each
WordingCategoryWhat has to happen before it can be used
Low in a named nutrientNutrition claimThe defined threshold for that claim must be met
Contributes to a named bodily functionHealth claimMust appear on the authorised register, with conditions met
Reduces the risk of a named conditionDisease risk reduction claimA distinct and more demanding authorisation route
Good for you, in general termsGeneral non-specific claimOnly permitted alongside a specific authorised health claim
Made the traditional wayDescriptive wordingNo authorisation, only the general rule against misleading
Treats or prevents a named diseaseMedicinal claimOutside food law altogether, and not permitted on a food

Structure set out by this newsroom from the published rules named in the sources below. It is not a survey, a measurement or a market study.

What authorisation involves

The mechanism is a scientific assessment of whether the claimed relationship is substantiated, followed by a decision on whether to authorise. In Great Britain, applications are assessed with advice from independent scientific committees before a decision is taken by ministers, and authorised claims are then added to the register.

The assessment asks a narrow question. It is not whether the food is good, or whether the manufacturer is reputable, or whether the product is worth buying. It is whether the specific relationship asserted between a defined substance and a defined effect is supported by the evidence, and, if so, at what intake and under what conditions of use.

That narrowness is why authorised claims read the way they do. The wording is often stiff and qualified because it is tied to the exact relationship that was assessed. A claim written in appealing prose has usually drifted from the authorised wording, which is precisely what the rules on wording are designed to prevent.

Conditions of use are part of the claim

An authorised claim comes with conditions, and the conditions are not decoration. They typically specify how much of the substance must be present, what quantity of the food would need to be consumed to obtain the effect, and what additional information must be given to the consumer.

Some claims also require an accompanying statement, for example about the amount that would need to be eaten. Where a claim is being used lawfully, that supporting text is not a disclaimer added by a cautious lawyer. It is part of the authorisation.

This creates a useful reading habit. Where a health claim appears in small type with an attached condition, the small type is where the substance is. Where a health-adjacent phrase appears in large type with nothing attached, it is probably not a claim in the regulated sense at all.

What sits outside the system

An enormous amount of food marketing wording is outside the claims regime entirely, and this is the part that most rewards attention.

Phrases about how a food was made, where it comes from in a general sense, how it makes you feel, what kind of person eats it, or what tradition it belongs to are not nutrition claims and not health claims. They assert nothing about a nutrient or a bodily function, and so no register applies to them.

They are not unregulated. Food information must not be misleading as to the nature, identity, properties, composition, quantity, durability, country of origin, method of manufacture or production of a food. Advertising is separately subject to the CAP and BCAP codes, enforced by the Advertising Standards Authority, and consumer protection law applies on top of that.

But the difference in mechanism is enormous. A health claim has to clear a defined evidential bar before it can be used. A descriptive phrase only has to avoid creating a false impression, which is a judgement made after the fact, usually only if someone complains.

Supplements and borderline products

Food supplements are foods, and the claims regime applies to them in the same way. The wording on a supplement pack that describes an effect on the body is either an authorised health claim or it is not permitted.

Where a product goes further and claims to treat, prevent or cure a disease, it is no longer being marketed as a food at all. Medicinal claims move a product into a different regulatory regime with a different regulator. That boundary is a real one and it is policed.

This publication does not evaluate supplements, does not recommend any product and does not offer a view on whether anyone should take one. That is a question for a GP or a registered dietitian who knows the individual.

How to read a claim in ten seconds

The test is mechanical. Does the wording connect the food, or something in it, to a nutrient level or to a function of the body? If yes, it is a claim and it should be traceable to a permitted nutrition claim or to the authorised register, with its conditions visible nearby. If no, it is descriptive wording and the only question is whether it creates a false impression.

Most front-of-pack wording fails the first test, which is not a criticism. It simply means the pack is doing branding rather than making a regulated assertion, and it should be read on those terms.

Where this stops

An authorised claim is a statement about a relationship assessed at population level under stated conditions. It is not advice to you, it is not a treatment, and it does not mean a food is suitable for your circumstances. Anything concerning your health, your diet or a condition you are managing belongs with your GP, a registered dietitian or the NHS.

Elsewhere on Feedworthy. Traceability in UK food law: one step back, one step forward. Recalls, withdrawals and alerts: how a product comes off the shelf. When a food post has to be labelled an advert.

Common questions

Where can I check whether a health claim is authorised?

The Great Britain nutrition and health claims register is published by the government and lists authorised claims along with their conditions of use. It is the definitive source, and it is public.

Why is authorised claim wording so awkward?

Because the wording is tied to the exact relationship that was assessed, at the intake and under the conditions that were assessed. Rewriting it into more appealing prose risks changing the meaning, which the rules on wording exist to prevent.

Is a phrase like naturally good not a health claim?

Generally not, because it asserts no relationship between a specific substance and a specific bodily function. It is descriptive wording, governed by the general prohibition on misleading food information and by the advertising codes, rather than by the claims register.

Do the same rules apply to food supplements?

Yes. Supplements are foods, and the nutrition and health claims regime applies to them in the same way. A product that claims to treat, prevent or cure a disease has left food law altogether and is subject to a different regulator.

Who enforces claims on food packaging and advertising?

Labelling is enforced primarily by local authority trading standards and environmental health, working within the framework overseen by the Food Standards Agency. Advertising is separately subject to the CAP and BCAP codes, administered by the Advertising Standards Authority.

Sources

Links to regulators, legislation and official guidance. They are cited because they are public and verifiable, not as an endorsement of this article. Where any subject reaches diet or health, the NHS and a registered dietitian are the right sources rather than this publication.

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