Foodaction has calculated over 800 nutrition panels and have found that few are easy. Here are some of the details that you may want to consider when working with nutrition data

A basic nutrition panel isn’t too difficult to create if you know how, but often it is not a basic nutrition panel that is needed. In this example, we look at how a nutrition panel for a pie could be put together.

Below are 6 potential customisations and steps you may wish to, or are required to take.

• Customise for gluten free claims
• Add dietary fibre content if required or wanted
• Add sugar claims if needed
• Add nutrition claims
• Add health stars
• Pass the NPSC and add health claims

Getting a lab tested nutrition panel usually costs $500-$600 and is very rarely needed, so most companies and startups calculate them instead for a much lower cost.

If you need to calculate a nutrition panel for the first time you’ll probably end up overwhelmed with what looks like a lot of mathematics, but this isn’t really the toughest part.

When it comes to nutrition panels, there are many rules that need to be taken into consideration beyond the calculations, and a deep knowledge of the Food Standards Code is needed. For instance, if you list your energy content in your product as 1256 kJ you have already made a very mistake. There is a rule stating you should have rounded to 1260 kJ. The code is packed with rules like this.

I’ve always been good at maths and yet the first nutrition panel I ever did was a huge amount of work and I know for sure that I made a number of mistakes that I have since had to pay to fix.

There are often really subtle issues that need to be taken into consideration. For instance, in NZ we count carbohydrates differently to the US. This means that if you get a specification for Californian Almonds and use this in your calculations, you will get the wrong result – this can create significant errors.

Foodaction has calculated over 800 nutrition panels over the years and we have learned a few tricks along the way. There is no school you can attend to become an expert. The Food Standards Code is a 500+ page beast and there are dozens of guidance documents out there that can be found if you know where to look. 

The Humble Pie – the Perfect Food Labelling Example

In this example, I will show you a typical process for creating and tweaking a nutrition panel for a classic Kiwi pie. Its a made up recipe with a few convenient ingredients thrown in to demonstrates some key points – so don’t try to make this one!

At Foodaction, we wrote our own software for performing labelling work, but we offer much more than just a software service and believe that software is just a tool for helping a professional.

To calculate a pie nutrition panel we need a few pieces of information

• The recipe in weights (no teaspoons, cups or pinches)
• Ingredient labels, descriptions or specifications
• The serving size e.g. 200-225g for a pie
• The number of serves. This is obvious for this product, but can be less so for other foods.
• A basic description on how the food is made.
• Moisture / weight loss or gain

This description can be really important. For instance, when the filling is made, it is simmered for 2 hours, and during that time water evaporates. This means the remaining nutrients are concentrated and the total weight is reduced. In this example for every 1kg of filling ingredients, it leaves behind 800g of cooked filling.

The last step is that the pie is placed in the oven and cooked. This results in more moisture being lost, and this needs to be taken into account too. In this example, we used a 5% water loss

Nutrition panels are not all created equal. A basic nutrition panel might be all you need if you are doing a basic product that has basic marketing needs, but many products end up being difficult to sell as a result of the nutrition panel work early in the process.

Here is our completed nutrition panel for this pie example. It might look familiar, but like a high end car, there is plenty going on under the hood.

This nutrition panel is professionally designed for nutrition and health claims that can be extremely valuable both on the label, and in print or digital marketing.

The following nutrition claims can be made with this style nutrition panel.

• High in Protein
• Gluten Free
• Low in Sugar
• Contains Magnesium, Zinc, Fibre and Energy
• Good Source of Iron

It also allows you to make these sorts of health claims

• Supports Immunity
• Reduces Tiredness and Fatigue
• Brain food
• Bone health
• Skin, hair and Nail Support
• Vision support
• Supports muscle repair, maintenance and growth

While these sorts of claims may not be suitable for a hypothetical pie, they are used in other products to great success. Compliant health claims take a lot of work, and the list above does come with some conditions.

So, how did we get here? It’s a lot of work but we designed our own internal software to help out with all the steps.

Over the years the expectations from MPI over gluten free products has changed a little. There was a major incident a few years back with buckwheat flour contamination and since then testing has become a requirement, but there is still some confusion over frequency and whether lab tests are required, or instant tests are sufficient.

One rule that is set in stone though, is the really stupid one that doesn’t really have any impact on safety at all.

If you want to make a gluten free claim on your label, then you need to add the following line to the nutrition panel below Protein,

“-gluten”

Take a look at our panel above and you will see it but you will probably find it missing from a lot of products in specialty stores. It is a legal requirement to have this line.

There is another change required to the nutrition panel that many companies miss when making a gluten free claim. Can you spot it above?

Dietary fibre is not usually a mandatory line in a simple nutrition panel which is great news because it is by far the most expensive and difficult attribute to test for.

If you do need to test, it is sometimes not just as simple as sending a sample to the lab and telling them to test for fibre. For some technical ingredients like isomalto-oligosaccharides or products containing this, it can turn into an ordeal and often requires samples being sent abroad.

There is some reliable fibre data out there you can use if you know where to find it and how to use it, but it adds difficulty to the calculations.

In this example the pie contains enough fibre to make a claim about it. This just means that you can tell the customer that the product contains fibre.

To be able to say anything like “our pie contains fibre” you need to have 2g of fibre per serve. In this case, the product qualifies.

If you hit 4g you can say “good source of fibre”. Our pie is close, and through some reformulation, you might be able to hit this mark.

7g of fibre is rare in a single serve of product, but will let you state “excellent source of fibre“. This might be possible in some larger products like ready meals where the serve is much bigger than a snack product.

Sugar claims come with a lot of rules, and some impact the nutrition panel

The rules around ‘low in sugar’, or any claim relating to sugar such as ‘no added sugar’ are a bit weird.

If you want to make any claim about sugar, then you need to add dietary fibre to the nutrition panel, which as discussed above, is often difficult.

Its not clear why this rule is in place, and what makes this even weirder is that this rule is not in an obvious part of the food standards code.

Also, you can’t just say that a product is low in sugar just because you think so either. The food standards code has specific limits on what does and doesn’t constitute low in sugar, and the levels are different for drinks and foods. We often find ourselves performing nutrition panel calculations then advising the client to adjust an ingredient so that a claim like this can be made. If the % sugar in our pie was increased by just 0.1%, we could no longer state low in sugar. This usually results in several rounds of nutrition panel calculations.

This fibre rule applies to any claim about sugar so you need to be careful especially because of how sugar is defined. If you are thinking sugar is just that stuff you put in coffee, you’ll be wrong. There was a sports nutrition product on the market that claimed ‘no added sugar’. The problem here is that the product was made almost entirely of maltodextrin and in the food standard code, maltodextrin is defined as 100% sugar. Unless you have read the Food Standards Code cover to cover and understood it all, you might miss something like this.

Nutrition content claims can be very marketable for the right types of products. Granted, pies probably aren’t the type of product where people are looking for claims, but every little helps, and our custom software calculates these levels automatically right from the start and gives real time values as a recipe is developed.

This becomes an excellent tool for product development. For instance, if you know that your product requires exactly 10% recommended daily intake of magnesium, and the product contains cocoa, then you can set your cocoa level to exactly the correct amount to hit the 10% mark (cocoa is particularly high in magnesium). This could be a small increase or decrease.

A rough analysis of the pie concludes that the following micronutrients are probably in there in there in claimable quantities: Niacin, Vitamin B12, Iron, Magnesium, Phosphorus, Zinc.

If you want to make nutrition claims about any of these, you not only need claimable quantities, you also need to add them to the nutrition panel.

Minerals are not lost in cooking whereas vitamins are, so you can rely on calculations for minerals (within reason), whereas you should backup vitamin claims with lab tests, and unfortunately lab tests for vitamins are really expensive compared with mineral tests.

The opposite is also true with vitamins and minerals in nutrition panels. If your product does not contain claimable amounts of vitamins and minerals, then you are not allowed to mention them anywhere on the product including in the nutrition panel. We often see this mistake in sports nutrition products where companies add ridiculously low levels of minerals like magnesium and calcium because their customers think they are needed (they usually aren’t). If you don’t put enough in, then the only reference to them is in the ingredient listing and you cannot communicate how much you put in at all.

If you have a super healthy food, then you might consider adding health stars, but in our experience most companies end up choosing not too.

The health stars system can be brutal on some products. Take a ‘healthy’ vegan protein bar for instance. We have developed a few of these over the years and always have to deliver bad news to the client.

Health stars are calculated by adding up all the bad things about a product (sugar, energy, saturated fat) and giving that a score, then adding up all the good things (protein, fibre, fruit and vege). The difference between the good and bad score gives the final rating. The number of stars you get is based on both the type of food and the final score.

Take the vegan protein bar based on pea protein. To get these even remotely edible, you need to add a lot of either coconut fat, palm oil, or cocoa butter otherwise they are too dry to swallow. I prefer cocoa butter but its really expensive. The problem is with all of these ingredients the saturated fat is really high. You then have a product with a massive calorie count per 100g because it is so dry and energy dense. These are designed to eat in 40g portions, not as 100g snacks. You then need to stick all the ingredients together and your options are often only high sugar dried fruit or something like rice syrup.

The high protein and moderate fibre level of these bars should get you some good points to counter all this badness, except there is a rule that states you lose all your protein and fibre points if your bad points are too high. We learned about this rule the hard way.

All this means your healthy, vegan protein bar, is going to get about 1.5 stars.

The other reason people eventually decide against health stars even if they have a 4 or 5 star product is that they may also have another product in their range that is low e.g. 2-3 star. They don’t want the inconsistency of stars on one product and not on the others, or high stars on some, and low stars on others.

If your product contains significant levels of magnesium either naturally or through fortification, then it might allow you to make a health claim such as “contributes to a reduction of tiredness and fatigue”. This could be extremely valuable for some products.

There is a big hoop to jump through though. First, your product must pass the NPSC.

The NPSC, or Nutrient Profiling Scoring Criterion is a calculation on how healthy a food is. Very basically, if a food gets a healthy score and qualifies for nutrition claims, it is allowed to make a health claim. If it doesn’t score high enough it can’t make a health claim.

In the case of our original pie example, it fails this test. We were able to see this as soon as we added the recipe to our software and were able to quickly see which tweaks to the recipe were required. For instance, we can drop the sugar content by adjusting the sauce quantity, increase the fibre and protein with the addition of lentils, decrease the saturated fat by a change to meat type and easily reduce the salt. With these changes, the product is able to take full advantage of the high levels of nutrients like zinc and magnesium which are heavy hitters when it comes to health claims.

The NPSC calculator is very similar to the Health Star Rating calculator, so if the product fails, a low health star rating can be expected but we have seen some exceptions to this.

Things that impact the NPSC score negatively are high levels of sugar, calories/energy, salt and saturated fat. Things that impact the NPSC score positively are high levels of fruit and vege, protein and fibre. Sometimes it is as easy as looking at the charts behind the calculations and seeing exactly what the limits are. For instance, if you need to hit 90mg sodium, then you just lower your salt level to hit this target, then look for other easy targets to meet.

A basic panel contains Energy, Protein, Fat, Saturated Fat, Carbohydrate, Sugars, and Sodium. No fibre, no micronutrients, no gluten free claims. This also means no sugar claims and very limited health claims. You can make a few nutrition claims if you are willing to spend a fair bit of time reading through the Food Standards Code. In this example, high in protein, low in sugar and contains fibre might be possible after some of the tweaks we made to the formulation.

You can create this basic nutrition panel yourself, with great amounts of effort for most, using the free online NPC Calculator. It does come with some big difficulties though. Some of the ingredient definitions are difficult, you don’t get fibre or micronutrients and dealing with compounded recipes is often required.

You also don’t get the ingredient listing and frankly, this is usually more difficult and important than the nutrition panel.

In our pie example above, you will notice there are two recipes. This is really important and not just because there is water loss during the filling manufacture then again during the pie cooking. In this example you need to create a nutrition panel for the filling, then use this as a custom ingredient in the second recipe. This means that if you change an ingredient in the filling, it changes two nutrition panels that are connected to each other. Originally our software could not automatically update both panels and ingredient listings, but we have recently developed the system to cope with this very common situation.

The alternative approach is to convert the two recipes into a single recipe, but then you have the two step water loss to deal with. Even if your maths skills are sharp enough to do this using a spreadsheet, you skills with the rest of the Food Standards Code will probably lead to other mistakes.

Ingredient Listings are Harder Than Nutrition Panels

There is a reason we chose pies for this example. We’ve done nutrition panels for hundreds of products, and with most products, the ingredient listing is much more difficult to compile than the nutrition panel. Pies are especially difficult though. For this hypothetical example above, this is what you end up with.

Ingredients: Pie Filling [Beef, Water, Onion, Kumara, Carrot,Tomato Sauce [Concentrated Tomatoes, Sugar, Salt, Acidity Regulator (Acetic Acid), Spices, Natural Flavours], Stock [Salt, Sugar, Maize Starch, Hydrolysed Vegetable Protein (Soy), Yeast And Yeast Extracts, Dehydrated Onion, Sunflower Oil, Colour (150d), Thickener (415), Herbs, Spices, Flavour Enhancer (635)], Garlic, Lentils, Salt, Celery, Dried Rosemary, Turmeric, Black Pepper, Cumin, Dried Parsley, Dried Basil, Coriander Seed, Dried Coriander], Savoury Pastry [Buckwheat Flour, Margarine (Vegetable Oil, Water, Salt, Emulsifiers (471, Soy Lecithin), Acidity Regulator (330), Antioxidant (307b)), Water, Butter (Cream (Milk), Salt), Seasoning (Contains Gluten (Wheat), Milk), Raising Agents (450,500), Emulsifier (481), Preservative (202), Colour (160a)], Flaky Pastry [Buckwheat Flour, Margarine (Vegetable Oil, Water, Salt, Emulsifiers (471, Soy Lecithin), Acidity Regulator (330), Antioxidant (307B)), Water, Butter (Cream (Milk), Salt), Emulsifier (481), Raising Agent (336), Preservative (202)], Egg, Canola Oil, Emulsifier (Soy Lecithin)

Contains: Wheat, Gluten, Soy, Milk, Egg

This listing is really long, complicated and even if the ingredients are wholefood, will look unhealthy at a quick glance. Want some more bad news? We will probably have to add additional detail. For instance, if the client wants to call their pie ‘beef, vegetable and lentil pie’ then we need to add % amounts for the beef, lentils and some of the vegetables such as carrot. If we then make any change to the recipe, then we need to recalculate those % and the order of ingredients.

Most clients are shocked when they first see their ingredient listing created correctly. There are a lot of things we can do to tweak the ingredients and formulation though. For instance, we can swap out the tomato sauce with tomato paste and remove 11 words from the panel. There are other things we can do to consolidate the herbs and spices, and reduce the impact of using a commercial stock product. Every change can have an impact on the formulation or the ingredient order, so a it can take a lot of work to simplify the ingredient listing.

Allergen Statements Will Get You in Trouble

The legislation around allergen labelling changed recently and became a lot more prescriptive. I have been bolding allergens in ingredient listings so years as it was considered best practice, but it was never a legal requirement. The same was true for the summary statement e.g. Contains Dairy.

That changed and now there are a tonne of rules around allergen labelling.

Did you notice our deliberate mistake above in the ingredient listing? The product is made using a ‘gluten free’ pastry, but if you look really closely, the seasoning contains wheat and gluten. If a verifier spotted this, then a call would have to be made to MPI and you’d end up chatting to an Officer. You would also automatically fail your audit and your audit frequency would probably increase.

Copying either products is a bad option too. The laws changed, but there is an introduction period, so if you saw another product that says ‘contains dairy’ and you copied this, you would be breaking the rules. The statement must be “Contains: Milk“. This is even if the product contains butter, but no milk.

To make it even more complicated, there are absolutely no rules around the ‘may contain gluten’ type statements. None at all. This doesn’t mean you can’t get in a tonne of trouble for not having one of these statements though, it just means the unwritten rules are very nuanced. In the first few lines of the Food Act 2014 it states that all foods must be safe and suitable. If your product contains allergen contamination (from your operation or from an ingredient) and you are not clearly communicating this fact, then your food is not safe for people with an allergy. This type of situation occurred a couple of years back when someone suffered a severe anaphylactic to some chocolate that was supposedly dairy free. This incident resulted in 20+ companies recalling products.

Barcodes Can Create Significant Delays

No one thinks about the costs associated with barcodes until they are faced with the costs? Our manufacturing company spends about $700 a year with GS1 on barcodes, Product Recall subscription and registration to the National Product Catalogue.

If you or your designer gets your barcodes wrong, it can stop you getting into the supermarkets. Imagine being told you can’t get your product on the supermarket shelves because your designer got the dimensions and aspect ratio of your barcode is wrong.

If you are looking to save a few dollars, you will be able to create something that looks like a compliant nutrition panel, but often these will cause problems later on. There is a free tool online called the Nutrition Panel Calculator which can be used, but is so simple that it can get you in trouble quickly. It has as much functionality as a basic spreadsheet and I wouldn’t recommend it in most instances.

We’ve dealt with clients who have either tried DIY or used nutritionists to create nutrition panels. Usually the costs further down the line make this an expensive option. Your nutrition panel will need to get through an external verification where a verifier may point out errors that you will need to fix up. This is expensive if you have already printed your packaging.

We think we are quite unique in our approach to nutrition panels. We not only perform the calculations, we also advise on subtle changes to the formulation that can mean the difference between passing the NPSC and failing it, hitting legislative limits for claims like low in sugar, high in magnesium, and can carefully construct compliant health claims for you such as ‘immunity support’. While we are doing this, we also create the complex ingredient listing and the allergen listings in realtime. We wrote our own software to do all this work at once, so any change to formulation doesn’t result in the need to start again, we just click a button and about a minute later all the calculations are complete.

Most clients also need help with Food Act registration for custom food control plans or national programmes, and help with shelf life. We have started a food business and operated it for over 10 years, so there aren’t many things we can’t advise on.

If you need help with your nutrition panel, whether basic or complicated, give us a call or email to discuss.