Taiwan Revises Regulations on Nutrition Claim for Prepackaged Food Products

On February 19, 2024, the Taiwan Food and Drug Administration (TFDA) promulgated the revised Regulations on Nutrition Claim for Prepackaged Food Products (hereafter referred to as the Regulations). Provisions in the Regulations took effect immediately upon promulgation, except for Paragraphs 1 and 4 of point 4, Point 5 and point 6, which are scheduled to take effect on January 1, 2026. 

Significant Revisions

The amendments have undergone consultation twice previously, whose details can be checked here. Compared with the old version, significant revisions in the new Regulations are as follows: 

• Nutrition claims of special dietary food shall be in line with the Regulations unless otherwise specified. For products that have obtained a special dietary food permit before promulgation, those manufactured from January 1, 2026, must adhere to the provisions. 

• Requirements for claims like "contain", "source" and equivalent expressions are simplified. To convey the presence of specific nutrients, products can be attached with factual nutrition claims on their packaging, such as "This product contains lutein" or "XX g of protein per serving of the product", with the corresponding nutrient content clearly stated in the nutrition labeling field. 

• New nutrients and content requirements are added in Table 3 for claims such as "high", "rich in" and other synonymous expressions. For instance, the requirements for claiming "high in Vitamin D" is added that the Vitamin D content shall be no less than 3ug per 100g. Here are some examples of new nutrients and content requirements applicable to non-specific population:

• Food categories listed in Table 7 with corresponding prohibited nutrition claims are revised. For instance, sugary carbonated drinks may have nutrition claims like "Vitamin C added" or "50 mg of Vitamin C per 100 ml". However, expressions like "rich in Vitamin C" or "higher than…" or other synonymous nutrition claims or any descriptive wording of the physiological functions are prohibited. 

Frequently Asked Questions

TFDA also issued FAQs to assist stakeholders in understanding the Regulations comprehensively. Below are some illustrative examples:

Q1: In addition to the 8 nutrients for moderate intake and the 23 nutrients for supplementary intake outlined in the Regulations, can other nutrients have nutrition claims like "free" "low" and "high"? 

A: No, only specified nutrients in the Regulations allow claims such as "free," "zero," "low," "little," "high", "rich in" and other equivalent expressions.

Q2: Is it acceptable to present nutrient content in percentage terms, such as 10% protein, without indicating the unit weight, volume, quantity, and serving size of the food?

A: No, the nutrient content should be described as a value in unit weight, volume, quantity, or per serving size of the food. For example, "XX g of protein per 100 g of the product" or "XX mg of calcium per serving (50 g) of the product."

Q3: If a product claims "contains 18 essential amino acids" on the packaging, is it allowed to only list the total amount of these amino acid in the nutrition labeling field? Or is it necessary to list the names and content of the 18 amino acids separately?

A: The names and respective content of the 18 amino acids must be explicitly indicated in the nutrition labeling field. It is not permissible to only show the total amount of these amino acids.

Q4: Do effervescent tablets need to comply with the Regulations? Can a product claim "zero calories," "low sodium," and "rich in vitamin C" simultaneously? If yes, how should these claims be made? For instance, a product is limited to one tablet per day, with a sodium content of 150 mg per tablet, and is recommended to be dissolved in 150 ml of liquid.

A: According to the Regulations, if a product has two or more nutrients that meet the conditions for nutrition claims, these claims should be made on the same product state (solid, semi-solid, or liquid). Additionally, effervescent tablets must be in line with the provisions for capsules and tablets outlined in the Regulations. For the case mentioned in the question, one of the following methods can be chosen to determine whether it can have simultaneous claims of "rich in vitamin C," "zero calories," and "low sodium":

• product in solid state: The Vitamin C content must be at or above 30 mg per tablet; the calorie content must not exceed 4 kcal per 100 g of the product; the sodium content must not exceed 120 mg per 100 g of the product.

• product in dissolved liquid state: When one tablet is dissolved in 150 ml of liquid, the Vitamin C content must be at or above 30 mg; the calorie content must not exceed 4 kcal per 100 ml of the dissolved liquid; the sodium content must not exceed 120 mg per 100 ml of the dissolved liquid.