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Nov 10, 2025 - Foods

Proteinclaimsonthefrontofpackagefood

Proteinclaimsonthefrontofpackagefood

Primarily, nutritional information serves to inform the consumer about the composition of a foodstuff. Food business operators are navigating within the realms of the FIC (Food Information to Consumers Regulation - Regulation (EU) No. 1169/2011) and the NHCR (Nutrition and Health Claims Regulation - Regulation (EC) No. 1924/2006) when making isolated protein claims.

The FIC contains basic rules for the labeling of food in the European Union.

The NHCR is a regulation that sets requirements for health claims about food.  

The FIC imposes very strict limits on repeated nutritional information through Article 30 Paragraph 3. According to Article 30 Paragraph 3 of the FIC, the following nutritional values ​​may be repeated when a mandatory nutritional declaration in accordance with Paragraph 1 is present:

a)      The energy value or

b)      The energy value along with the amounts of fat, saturated fat, sugars, and salt.

The FIC does not provide for a separate claim of a single nutrient outside the nutrition table.  The NHCR also sets strict limits on nutritional claims.  

According to Article 8 Paragraph 1 of the NHCR, nutrition claims may only be made if they are listed in the annex to the regulation and meet the conditions for the claims. Thus, the claim that a food is high in protein is generally permissible if the protein content accounts for at least 20% of the total energy value.

The discrepancy in the regulations between FIC and NHCR is obvious.  

So far, three courts - the Hamburg Higher Regional Court, the Munich Higher Regional Court, and the Stuttgart Higher Regional Court - have addressed the dispute over the isolated indication of protein content. All three instances came to the same conclusion that indicating the isolated protein content on the front of the packaging constitutes an unauthorized repetition of the nutritional declaration according to Article 30 Paragraph 3 of the FIC and is considered an unauthorized nutritional claim under the meaning of the NHCR.

The German Federal Court of Justice is currently reviewing whether such protein claims on the front of food are inadmissible. Whether the case will be heard before the CJEU remains unclear.

 

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