Guidance on comparative nutrition claims


Manufacturers can help people to select healthier options by highlighting on their packaging reductions or increases in nutrients, for example: less sugar; fewer calories; more fibre. Such claims can also encourage businesses to reformulate their recipes or offer alternative options with a healthier nutrient profile.

This step by step guide by the Food and Drink Federation (FDF) offers a consistent approach to making comparative nutrition claims. Businesses may find this helpful when considering the requirements of the legislation and in providing accurate information on their product packaging.

As guidance, this document cannot offer an authoritative interpretation of the law, which only the courts can provide. The views expressed in the guidance are those of the FDF and the foreword should not be taken as an endorsement by the Department of Health of the content.
Tim Baxter, Deputy Director – Healthy Behaviours, Department of Health

In this guide

1. Scope of this guidance

This document provides detailed best practice guidance on the requirements and substantiation for, and appropriate wording of, any comparative nutrition claims to be used in the labelling and advertising of pre-packaged food and beverage products in the UK. Comparative nutrition claims stipulate a difference in the quantity of a nutrient or energy value:

This guidance also describes comparative nutrition claims which are not permitted, such as reduced claims against a previous recipe that is no longer available in the marketplace and equivalence claims such as “as much 'nutrient' as 'other category” claims.

This guidance does not cover non-nutrition comparative claims, such as ingredient (e.g. 30% more fruit), taste, texture, or pricing comparative claims, or to health claims that draw comparisons.

Comparative claims may also include comparisons made against previous recipes, on a portfolio basis for example, however this guidance will not consider the requirements for these types of claims.

2. Overarching principles of nutrition claims

The legislation on nutrition and health claims aims to ensure that consumers are not misled by unsubstantiated, exaggerated or untruthful claims, by ensuring that genuine nutrition and health claims are not competing with false or inaccurate claims.

A nutrition or health claim should not be made if it is inconsistent with generally accepted nutrition and health principles or if it encourages or condones excessive consumption of any food or disparages good dietary practice.

Next page: 3. Legislative requirements for comparative nutrition claims