There are several sources of labelling law in South Africa including the Consumer Protection Act, Foodstuffs, Cosmetics and Disinfectants Act and the Codex Alimentarius which is an aggregate of internationally recognized standards, codes of practice, guidelines and other recommendations relating to foods, food production and food safety.
To satisfy the minimum labelling requirements for packaged food the following should be stated on product labels:
- Name: description of food or name;
- Name and address of manufacturer, importer or seller;
- Instructions for use;
- List of ingredients;
- Net contents (using the International System of Units); and
- Common allergens.
It must be noted that when naming ingredients the intention is always to assist the consumer, therefore descriptive words must be used where they clarify a purpose such as “starter culture” in cheese.
Claims that a product possesses a characteristic that all similar foodstuffs also possess are prohibited unless the characteristic is commonly present, or the claim is generically worded.
Similarly, the identification of the product must not be misleading in any way. This includes pictures on the label or in an advert which must not be false, misleading or deceptive.
Where vending machines are used, the name of the foodstuff must be displayed on the front of the machine unless the name appears on a label on the foodstuff in a way that would be visible and legible from the outside of the machine.
The Consumer Protection Act states that where the food contains at least 5 per cent genetically modified ingredients or components it must be labelled to inform consumers of the presence of genetically modified ingredients or components.
Certain statements are prohibited such as those creating the impression that the product has been endorsed by health practitioners, unless these statements are approved.
Moreover, the words “wholesome” or “nutritious” as well as claims that a foodstuff provides complete or balanced nutrition are also prohibited.
It is noteworthy that it is not compulsory for food manufacturers to publish a ‘Typical Nutritional Information Table’ on a food label if they are not going to make any ‘High/Low’ claims about that food.