The Nuances of Fat Labeling on Food in China: Regulatory Requirements & Future Trends

The importance of proper nutrition labeling on food products cannot be overstated. As consumers need to make informed decisions about the foods they eat, accurate labeling is crucial in this regard. Among the various nutrients that need to be labeled, fat is one of the most important. It not only provides energy, but also has a significant impact on one's health depending on the type and amount consumed. Therefore, it is essential that food labels provide clear and accurate information about the fat content and its various components, such as fatty acids. In this article, ChemLinked explores the definitions of fat and fatty acids, China's current requirements for fat labeling on food products, and the potential trends in this area.

1. Dissecting the Terminology: Understanding Fats and Fatty Acids

Fats, also known as triglycerides, consist of fatty acids and glycerol. Fats found in food products are predominantly free fats, although some bound fats may also exist.
Fatty Acids are essentially long-chain carboxylic acids that, combined with glycerol, form fats. They can be categorized into saturated and unsaturated fatty acids.
Saturated Fatty Acids do not contain any double bonds in their carbon chain, such as palmitic and stearic acid. They can be labeled as saturated fat, saturated fatty acids, or saturated fat (acid).
Unsaturated Fatty Acids have at least one double bond in their carbon chain. This category includes monounsaturated and polyunsaturated fatty acids.
Trans Fatty Acids are a form of unsaturated fatty acids with one or more non-conjugated trans double bonds. They are typically produced during oil processing, such as in the hydrogenation of vegetable oil, but there are still small amounts of natural trans fats.

2. The Current Landscape of Fat Labeling

According to GB 28050-2011 General Standard for the Labeling of Prepackaged Foods, fat is a mandatory nutrient to be listed on the nutrition facts panel. However, the listing of saturated fats, trans fats, monounsaturated fats, and polyunsaturated fats is optional and at the discretion of the manufacturer. When a claim about a specific nutrient is made, such as "low in saturated fat" or "excessive intake of saturated fats can harm health," the amount and Net Realizable Value (NRV)% of that nutrient must be listed in the nutrition facts panel. In particular, fat-related claims can only be made after meeting corresponding conditions shown in the table below:

Item	Content claim	Requirements	Restrictive conditions
Fat	No fat or does not contain fat	≤0.5 g/100g (solid) or 100ml (liquid)	/
	Low fat	≤3 g/100g solid; ≤1.5 g/100ml liquid	/
	Lean	Fat content ≤10%	Refer to livestock and poultry only
	Skim	Liquid milk and yoghurt: fat content ≤0.5%; milk powder: fat content ≤1.5%	Refer to dairy products only
	No saturated fat or does not contain saturated fat	≤0.1 g/ 100g (solid) or 100ml (liquid)	Refer to the sum of saturated fat and trans fat
	Low saturated fat	≤1.5 g/100g solid ≤0.75 g /100mL liquid	1. Refer to the sum of saturated fat and trans fat 2. Refer to the situation that energy provided by saturated fat is less than 10% of the total energy
	No trans fatty acids or does not contain trans fatty acids	≤0.3 g/100g (solid) or 100ml (liquid)	/

For trans fatty acids, its content must be indicated in two scenarios:

a) If the product contains or is added with hydrogenated or partially hydrogenated oils during production, the amount of trans fats must be listed. If not, the listing is optional. Therefore, the rule of thumb is, "Use hydrogenated oils, label trans fats".

b) If a claim regarding the content of trans fatty acids is made, such as "no trans fatty acids" or "does not contain trans fatty acids," its content must be listed in the nutrition facts panel.

3. Anticipated Trends in Fat Labeling

The labeling of saturated fat content goes compulsory.

The current version of GB 28050-2011 only requires the mandatory labeling of fat content. However, its two both subsequent drafts include the listing of saturated fat amount and NRV, indicating that saturated fat may become a mandatory nutrient to be listed on all prepackaged food labels.

Four types of unsaturated fatty acids to be listed in the nutrition facts panel.

As disclosed by the drafts of GB 28050, n-3 polyunsaturated fatty acids, alpha-linolenic acid, eicosapentaenoic acid (EPA), and docosahexaenoic acid (DHA) might be allowed in the nutrition facts panel, expanding the current spectrum of fat-related nutrients that can be listed.

In a nutshell, understanding the different types of fats and their labeling requirements is crucial for both consumers and manufacturers alike. As China moves towards more transparency in food labeling, it is vital to stay updated on the evolving regulations and potential trends in this realm.