GUIDE TO FOOD LABELLING

A publication of the
Food Safety and Applied Nutrition Directorate,
NAFDAC, 2014

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Introduction

This Guidebook aims to provide food importers, manufacturers,

Packers, Vendors and retailers with a better understanding of the
labelling requirements of the Pre-packaged Food Labelling
Regulations 2005 and Nutrition, Health and other Food Claims
Regulations 2010 with the knowledge of the permitted and prohibited
claims for use in food labels and advertisements.

Industry members are responsible to ensure that their food products

comply with the safety, specification standards and the labelling
requirements stipulated under Pre-packaged Food Labelling
Regulations 2005 and Nutrition, Health and other Food Claims
Regulations 2010.

In addition, industry members are advised to make reference to the

Gazetted Pre-packaged Food Labelling Regulations 2005 and Draft
Nutrition, Health and other Food Claims Regulations 2010 Food for
the actual legal text where necessary.

We would like to remind importers, manufacturers, Packers, Vendors

that it is an offence to sell pre-packed foods without proper labelling or
to make false or misleading claims on food products. Any person who
contravenes or fails to comply with any of the provisions of the
NAFDAC Pre- packaged Food Labelling Regulations 2005 shall be
guilty of an offence and shall be liable on conviction.

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Terms and definitions
“Claim” means any representation which states, suggests or implies that a food has
particular qualities relating to its origin, nutritional properties, nature, processing,
composition or any other quality.

“Consumer” means persons and families purchasing and receiving food in order to
meet their personal needs.

“Container” means any packaging of food for delivery as a single item, whether by
completely or partially enclosing the food and includes wrappers. A container may
enclose several units or types of packages when such is offered to the consumer.

“Date of Manufacture” means the date on which the food becomes the product as
described.

“Date of Packaging” means the date on which the food is placed in the immediate
container in which it will be ultimately sold.

“Sell-by-Date” means the last date of offer for sale to the consumer after which there
remains a reasonable storage period in the home.

“Date of Minimum Durability” (“best before”) means the date which signifies the
end of the period under any stated storage conditions during which the product will
remain fully marketable and will retain any specific qualities for which tacit or express
claims have been made. However, beyond the date the food may still be perfectly
satisfactory.

“Use-by Date” (Recommended Last Consumption Date, Expiration Date) means the
date which signifies the end of the estimated period under any stated storage
conditions, after which the product probably will not have the quality attributes
normally expected by the consumers. After this date, the food should not be regarded
as marketable.

“Food” means any substance, whether processed, semi-processed or raw, which is

intended for human consumption, and includes drinks, chewing gum and any substance
which has been used in the manufacture, preparation or treatment of “food” but does
not include cosmetics or tobacco or substances used only as drugs.

“Food Additive” means any substance not normally consumed as a food by itself and
not normally used as a typical ingredient of the food, whether or not it has nutritive
value, the intentional addition of which to food for a technological (including
organoleptic) purpose in the manufacture, processing, preparation, treatment, packing,

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packaging, transport or holding of such food results, or may be reasonably expected to
result, (directly or indirectly) in it or its by-products becoming a component of or
otherwise affecting the characteristics of such foods. The term does not include
“contaminants” or substances added to food for maintaining or improving nutritional
qualities.

“Ingredient” means any substance, including a food additive, used in the manufacture
or preparation of a food and present in the final product although possibly in a modified
form.
“Label” means any tag, brand, mark, pictorial or other descriptive matter, written,
printed, stencilled, marked, embossed or impressed on, or attached to, a container of
food.

“Labelling” includes any written, printed or graphic matter that is present on the label,
accompanies the food, or is displayed near the food, including that for the purpose of
promoting its sale or disposal.

“Lot” means a definitive quantity of a commodity produced essentially under the same
conditions.

“Prepackaged” means packaged or made up in advance in a container, ready for offer

to the consumer, or for catering purposes.

“Processing Aid” means a substance or material, not including apparatus or utensils,

and not consumed as a food ingredient by itself, intentionally used in the processing of
raw materials, foods or its ingredients, to fulfil a certain technological purpose during
treatment or processing and which may result in the non-intentional but unavoidable
presence of residues or derivatives in the final product.

“Foods for Catering Purposes” means those foods for use in restaurants, canteens,
schools, hospitals and similar institutions where food is offered for immediate
consumption.

“Principal Display Panel”

The panel easier to be found on package or containers of prepackaged foods

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General Labelling Requirements

The following information is required on the labels of pre-packed

foods:

1. Declaration of Information on food label.

1.1 Information must be clear, accurate and not mislead consumers

The information on the label must be clear and unambiguous and must not be
such as it could mislead the consumer to a material degree. In addition, the
labelling must not attribute to any foodstuff, the property of preventing, treating
or curing a human disease or refer to such properties.

1.2. Information must be legible and easy to understand

The information provided on the label must be easy to understand, be clearly

legible, it must also be indelible, easy to see and not obscured in any way.

1.3 Information must be in English

The labelling of food must be in English.

1.4 Information on Pre-packaged food shall not be described or presented on

any label or in any labelling by words, pictorial or other devices which
refer to or are suggestive either directly or indirectly, or any other product
with which such food might be confused, or in such a manner as to lead
the purchaser or consumer to suppose that the food is connected with
such other product.

1.5 Prepackaged food shall not be described or presented on any label or in

any labelling in a manner that is false, misleading or deceptive or is likely
to create an erroneous impression regarding its character in any respect.

1.6 Labels in prepackaged foods shall be applied in such a manner that they
will not become separated from the container.

1.7 Where the container is covered by a wrapper, the wrapper shall carry the
necessary information or the label on the container shall be readily legible
through the outer wrapper or not obscured by it.

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 1.8 The name and net contents of the food shall appear in a prominent
position and in the same field of vision.

2. Name or description of food

2.1 The name shall indicate the true nature of the food and normally be specific and
not generic.

2.1.1 Where a name or names have been established for a food in a

Codex standard, at least one of these names shall be used.

2.1.2 In other cases, the name prescribed by national legislation shall

be used.

2.1.3 In the absence of any such name, either a common or usual

name existing by common usage as an appropriate descriptive
term which was not misleading or confusing to the consumer
shall be used.

2.1.4 A “coined”, “fanciful”, “brand” name, or “trade mark” may be

used provided it accompanies one of the names provided in
Subsections 2.1.1 to 2.1.3

2.1 The name of a food must be stated in order to inform the purchaser of the true
nature of the product.

For example, „milk chocolate‟ must have a certain compositional content,

e.g. not less than 25% total dry cocoa solids.

2.2 When a legal name does not exist, a customary name may be used, i.e. a name
that has come to be accepted by consumers without needing further explanation
such as “fish fingers”, “spaghetti” and “muesli”. In certain circumstances, in
order to avoid confusion, a description may be required to indicate the true
nature of the product and to distinguish it from other foods.

2.3. The use of a brand name, sales name, fancy name or trademark is permitted in
addition to the product‟s legal or customary name.

2.4 Details of the physical condition of the foodstuff or processes it has undergone
must accompany the name of the food such as powdered, freeze-dried, frozen,

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 concentrated, pasteurized and smoked where omission of such information could
create confusion in the mind of the purchaser.

3. List /Statement of Ingredients

3.1 Except for single ingredient foods, a list of ingredients shall be declared on
the label.
 The list of ingredients shall be headed or preceded by an appropriate
title which consists of or includes the term „ingredient‟.

 All ingredients shall be listed in descending order of ingoing weight

(m/m) at the time of the manufacture of the food.

 Where an ingredient is itself the product of two or more ingredients,

such a compound ingredient may be declared, as such, in the list of
ingredients, provided that it is immediately accompanied by a list, in
brackets, of its ingredients in descending order of proportion (m/m).
Where a compound ingredient (for which a name has been
established in a Codex standard or in national legislation) constitutes
less than 5% of the food, the ingredients, other than food additives
which serve a technological function in the finished product, need not
be declared.

 The following foods and ingredients are known to cause

hypersensitivity and shall always be declared:

• Cereals containing gluten; i.e., wheat, rye, barley, oats, spelt or their
hybridized strains and products of these;
• Crustacea and products of these;
• Eggs and egg products;
• Fish and fish products;
• Peanuts, soybeans and products of these;
• Milk and milk products (lactose included);
• Tree nuts and nut products; and
• Sulphite in concentrations of 10 mg/kg or more.

 Added water shall be declared in the list of ingredients except when

the water forms part of an ingredient such as brine, syrup or broth
used in a compound food and declared as such in the list of
ingredients. Water or other volatile ingredients evaporated in the
course of manufacture need not be declared.

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  As an alternative to the general provisions of this section, dehydrated
or condensed foods which are intended to be reconstituted by the
addition of water only, the ingredients may be listed in order of
proportion (m/m) in the reconstituted product provided that a
statement such as “ingredients of the product when prepared in
accordance with the directions on the label” is included.

 The presence in any food or food ingredients obtained through

biotechnology of an allergen transferred from any of the products
listed in Section 3.1.4 shall be declared.
When it is not possible to provide adequate information on the presence
of an allergen through labelling, the food containing the allergen should
not be marketed. (see details on number 11)

3.2 A specific name shall be used for ingredients in the list of ingredients in
accordance with the provisions set out in Section 2.1 (Name of the Food)
except as follows;
3.2.1 Except for those ingredients listed in section 3.1.4, and unless a general class
name would be more informative, the following class name may be used:

NAME OF CLASSES CLASS NAMES

Refined oils other than olive ‟Oil‟ together with either the term
„vegetable‟ or „ animal‟ qualified by term
„hydrogenerated‟ or partially
hydrogenerated‟ as appropriate

Refined fats „Fat‟ together with either , the term

‟vegetable‟ or „animal‟ as appropriate
Starches, other than chemically modified „Starch‟
starches
All species of fish where the fish “Fish”
constitutes an ingredients of another
food and provided that the labelling and
presentation of such food does not refer
to specific species of fish
All types of poultry meat where such „Poultry meat
meat constitutes an ingredients of food
and provided that the labelling and
presentation of such food does not refer
to specific type of poultry meat
All types of cheese where the cheese or „Cheese‟

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mixture of cheese constitutes an
ingredients of food and provided that the
labelling and presentation of such food
does not refer to specific type of cheese
All spices and spice extracts not „Spice‟, „spices‟, or „mixed spices‟, as
exceeding 2% by weight either singly or appropriate
in combination in food
All herbs or parts of herbs not exceeding „Herbs‟, or „mixed herbs‟, as
2% by weight either singly or in appropriate
combination in food

All types of gum preparations used in the „Gum base‟

manufacture of gum base for chewing
gum
All types of sucrose „Sugar‟
Anhydrous dextrose and dextrose „Dextrose‟ or „glucose‟
monohydrate
All types of caseinates „Caseinate
Milk products containing a minimum of „Milk Protein
50% of milk protein (m/m) in dry matter
Press , expeller or refined cocoa butter „Cocoa butter‟
All crystallized fruit not exceeding 10% „Crystallized fruit‟
or weight of food

3.1.8 Notwithstanding the provision set out in Section 3.2.1, pork fat, lard and beef fat
shall always be declared by their specific names.

3.1.9 For food additives falling in the respective classes and appearing in lists of food
additives permitted for use in foods, the following functional classes shall be used
together with the specific name or recognized numerical identification such as the
Codex International Numbering System (CAC/GL 36-1989) as required by national
legislation.

The following class titles may be used for food additives falling in the respective classes
and appearing in lists of food additives permitted generally for use in foods:

 Acidity Regulator
 Anticaking Agent
 Antifoaming Agent

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  Antioxidant
 Bleaching Agent
 Bulking Agent
 Carbonating Agent
 Colour
 Colour Retention Agent
 Emulsifier
 Emulsifying Salt
 Firming Agent
 Flour Treatment Agent
 Foaming
 Gelling Agent
 Humectants
 Preservative
 Propellant
 Raising Agent
 Sequestrant
 Stabilizer
 Sweetener
 Thickener

The expression “flavours” may be qualified by “natural”, “nature identical”, “artificial” or

a combination of these words as appropriate.
 Flavour(s) and Flavouring(s) Modified Starch(es)

3.1.11 A food additive carried over into a food in a significant quantity or in an amount
sufficient to perform a technological function in that food as a result of the use of raw
materials or other ingredients in which the additive was used shall be included in the list
of ingredients.

3.1.12 A food additive carried over into foods at a level less than that required to
achieve a technological function, and processing aids, are exempted from declaration in
the list of ingredients. The exemption does not apply to food additives and processing
aids listed in section 3.1.4

3.3 A list of ingredients is compulsory on all products, with the exception of

cheese, butter, beverages which contain more than 1.2% volume of alcohol,
carbonated water and „one ingredient‟ products, e.g. milk, salt.

3.4 The name of the ingredients must be specific enough to accurately describe
the ingredient and for consumers to identify potential allergens, for example,

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 where the ingredient „starch‟ (or modified starch) originates from a source
that contains gluten, the cereal origin of the starch must always be given in
the list of ingredients, e.g. wheat starch. Products containing meat as an
ingredient, such as ready meals and sausages, must declare the animal
species from which the meat is derived, such as „bovine meat‟ or „beef meat‟
or simply „beef‟ in the list of ingredients.

3.5 Additives performing technological functions in the final food must be

declared in the list of ingredients such that the name of the category of
additive is followed by the specific name of the additive or its E number, e.g.
Monosodium glutamate is often used as a flavour enhancer in food and must
be declared in the list of ingredients as Flavour Enhancer: E621 or Flavour
Enhancer: Monosodium glutamate (see example below).

3.6
„Flavourings‟ are used in or on foodstuffs to impart a taste and/or odour.
Flavourings must be indicated in the list of ingredients by the word
“flavouring(s)” or by a more specific name or description, for example,
„Flavouring: vanilla‟.
4 GR E DI E NTS
Example (Ingredient List)

Chicken breast (45%), Salt, Milk Proteins,

Soya Protein Isolate, Spices, Stabiliser: E450,
Flavour Enhancer: Monosodium glutamate,
Dextrose, Modified Starch, Colour: E160c,
Water, Hydrolysed Vegetable Protein,
Wheat Flour, Antioxidants: E301, E331, Herbs.

 This helps consumers identify the presence or absence of particular additives in a

food. Quinine and caffeine are flavourings which may cause hypersensitivity or
temporary behavioural changes and they must be declared in the list of
ingredients, e.g. “flavouring: quinine

3.6 In addition, drinks other than tea and coffee which contain caffeine in excess of
150mg/lmmust also provide a warning message on the label, followed by an
indication of the caffeine content such that: „High caffeine content (Xmg/100ml)‟.

4. Quantitative Ingredient Declaration (QUID )

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 4.1 In certain circumstances, it is necessary to state on the label, the quantity of
an ingredient which is used in the manufacture or preparation of a foodstuff.
The quantity must be declared in percentage terms and should appear in or
next to the name of the food or be in the list of ingredients. This is known as
quantitative ingredient declaration or QUID. QUID is designed to help
consumers to compare the composition of similar products on ingredients
likely to influence their choice.
Example is as shown below;

INGREDIENTS :
Pasteurised Egg, Whole Milk, Wheat Flour,
Cheese (13%), Onion (12%), Vegetable Oil and
Hydrogenated Vegetable Oil, Modified Maize
Starch, Salt, Dextrose

For example, the quantity of an ingredient as a percentage must be declared on the

label where the ingredient is:
 Included in the name of the food such as „ham pizza‟ where the ham
must be quantified
 Associated with the name of the food such as „summer pudding‟
where the fruit content must be quantified or
 Emphasised in words, pictures or graphics such as „with cheese‟ This
does not apply to „serving suggestions

5. Net Quantity

5.1 The net contents shall be declared in the metric system (“Système International”
units).

The net contents shall be declared in the following manner:

(i) for liquid foods, by volume;
(ii) for solid foods, by weight;
(iii) for semi-solid or viscous foods, either by weight or volume.

5.2 All pre-packaged foodstuffs must be labelled with information on the net quantity of
the foodstuff, i.e. its weight or volume, which does not include the packaging material.

5.2 The net quantity must be expressed using the metric system, i.e. litres or millilitres
for liquids or kilograms or grams for solids or either weight or volumetric measure for
semisolid or viscous foods such as tomato paste, yoghurt. In the case of weight
measure, suitable words such as “net weight” shall be used to describe the manner of
measure.

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5.3 Food packed in a liquid medium will be required to have both “net weight” and
“drained weight” declared.

Examples of products that require drained weight declaration:

 Products with liquid packing medium which is drained away prior to consumption
of the product. The products include canned seafood in brine e.g. abalone,
pacific clams, tuna, crabmeat and canned vegetables in brine such as button
mushrooms, whole corn kernels, chickpeas in water.

 Preserved/pickled products in liquid medium with salt, vinegar or sugar. The

liquid medium2 is neither drained away nor consumed. The products include
pickled green chilli, cucumbers, onions, mustard greens, salted plums etc.

 Canned fruit and vegetable packed in juices or sugar syrups. For this instance,
juice content is not a decisive factor to purchase. The products includes peaches,
pears, in light syrup, fruit cocktail in syrup.

Examples of products that do not require drained weight

declaration:
 Products for drinking which contain solid bits. For such products, the liquid
portion forms the most part of the product. Example of these products includes
fruit juice with aloe vera bits, juice drink with coco, and others.

 Products containing solid food in gravy, paste or sauce which are meant to be
consumed as a dish. Example of such products include, peanut soup, curry
chicken, sardines and baked beans in tomato sauce, fried gluten in soy sauce.

 Products containing solid food in oil predominantly. Example of such products

are canned seafood such as tuna, anchovies in vegetable oil, sundried tomato in
oil and fermented bean curd.

 Products containing solid food with small amount of water. Example of such
product is beancurd and jelly.

 For frozen food that has been glazed with ice, both the “gross weight” and “net
weight” shall be declared. The net weight declared for such product must
exclude the weight of the ice glazing. For example, the net content declaration of
glazed fish fillet will be declared as “Gross weight of
o fish: 1000g; Net weight of fish: 800g.

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6. Date of Minimum Durability

6.1 The date of minimum durability of a foodstuff is the date until which a
foodstuff retains its specific properties when properly stored . Most foods
must be date marked. However, there are some exemptions, e.g. an
indication of the date of minimum durability is not required for beverages
with greater than 10% volume of alcohol, vinegar or cooking salt.

6.2 The pre-packed foods are mandatorily required to be labeled with their expiry
dates. Expiry date refers to the date after which the food may not retain its
normal nature and quality. The expiry date should be qualified by words like
"USE BY", "SELL BY", "EXPIRY DATE", "BEST BEFORE" or other words of
similar meaning.

6.3 A „best-before‟ date is the date up until which a food can reasonably be
expected to retain its optimum condition. Most non-perishable foods with a
long shelf-life which do not require refrigeration, fall into this category, such
as biscuits and dried pasta.

6.4 A „use-by‟ date however, is required for foods which, from a microbiological
point of view, are highly perishable and are therefore likely after a short
period, to be an immediate danger to human health. Foods with a short shelf-
life that require refrigeration fall into this category, such as raw and cooked
meats, milk and yoghurts.

7. Special Storage Instructions or Conditions of Use

7.1 The label should outline any special storage conditions to enable the
consumer to maintain the quality of the product. Details on how the product
should be stored once the packaging is opened should be outlined such as
„refrigerate after opening‟, „store in a cool dry place‟.

7.2 Other options for the storage of the food can also be detailed in order to
maintain the specific properties of the opened food such as, „suitable for
freezing‟.

8.0 Batch Number

Each container shall be embossed or otherwise permanently marked in code or in clear

to identify the producing factory and the lot.

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9. Name and Address
.
9.1 The label must contain the name or business name and address of the
manufacturer or Packer, Distributor, Importer, Exporter, Vendor inside or
outside the country. The contact details must be precise enough to enable a
complainant to contact the named agent where necessary. A website address
alone is not acceptable.

9.2 The name of the country of origin of the food should be indicated on the
labels of foods. The name of a city, town or province alone is not acceptable
alone without the country of origin.

10. Instructions for Use

10.1 Where necessary, the label must contain instructions on how to use the product
to enable the consumer to make appropriate use of the food such as cooking,
reheating or preparation instructions or declarations such as „not suitable‟ for a
particular purpose.

11. Allergen Declaration

11.1 It is recognized that certain ingredients or substances can cause allergies or

intolerances in consumers. These allergenic ingredients must be declared on
the label so that consumers who have allergies or intolerances are able to
identify the ingredients they are sensitive to.

11.2 The allergen(s) must be indicated on the label with a clear reference to the
name under which the allergen is known either in the name of the product
example, cake with almonds in the list of ingredients or somewhere else on
the label e.g contains eggs, contains nuts.

11.3 There are some exceptions where the nature of the food indicates it contains
an allergen for example, dairy products such as cheese , butter or yoghurt
are clearly milk product and milk would not need to be declared separately as
an allergen.

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 The categories of ingredients (and products thereof) legally defined as ingredients
that are known to cause allergic reactions are as shown below:

(i) Cereals containing gluten This group includes wheat,

rye, barley,oats, spelt or their
hybridised strains and their
products.

(ii) Crustacean and crustacean products This group includes crayfish,

prawns, shrimps, lobsters,
crabs and their products.

(iii) Eggs and egg products This group includes eggs from
laying hens as well as eggs
from duck, turkey, quail,
goose, gull, guinea fowl and
their products.

(iv) Fish and fish products This group also includes

molluscs such as oysters,
clams, scallops and their
products.

(v) Peanuts, soybeans and their products Peanuts may be declared using
similar terms such as
“groundnuts”. Terms such
as “soya” or “soy” can be used
for soybeans.

(vi) Milk and milk products (including This group includes milk from
lactose) cows, buffaloes, or goats and
their products.

(vi) Tree nuts and nut products This group includes almond,
hazelnut,walnut, cashew nut, pecan
nut, Brazil nut,pistachio nut,
macadamia nut and their products
.
(vii) Sulphites in concentrates Food products that have sulphur of

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10mg/kg or more dioxide and/or sulphites directly added
and/or carried over from food
ingredients at a total concentration
of 10mg/kg or more(calculated in
terms of total sulphur dioxide).

(viii) Celery and celeric

(ix) Mustard
(x) Sesame seeds
(xi) Lupins

12 Nutrition labelling

12.1 Nutrition labelling is required only when nutrition claims, or permitted health
claims are made.

This information requires nutrient declaration in an acceptable nutrition information

panel, for pre-packed foods for which nutrition claims are made. The information to be
declared in the panel includes the energy, protein, fat and carbohydrate contents of the
food. Declaration of other nutrients is mandatory when such nutrients are the subject
of a nutrition claim.

More information on this Paragragh can be found on the Nutrition

Information Labelling guideline.

13. Other Compulsory Labelling Requirements

Other particulars which require a mandatory declaration are:

13.1 Food packaged with packaging gases must be labelled “packaged in a protective
atmosphere”

13.2 Food containing sweeteners must declare “with sweeteners” near the product
name

13.3 Food containing sugar and sweeteners must declare “with sugar(s) and
sweetener(s)”near the product name

13.4 Food containing aspartame must declare “contains a source of phenylalanine”

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13.5 Food containing more than 10% polyols must declare “excessive consumption may
produce laxative effects”

13.6 Confectionery or beverages containing glycyrrhizinic acid or its ammonium salt or

the liquorice plant Glycyrrhiza glabra (above certain levels) must declare “contains
liquorice – people suffering from hypertension should avoid excessive consumption”.

13.6.1 For confectionery containing glycyrrhizinic acid or its ammonium salt at

concentrations of 4g/kg or above, the statement „contains liquorice – people
suffering from hypertension should avoid excessive consumption‟ must be
added after the list of ingredients. In the absence of an ingredients list the statement
must appear near the name under which the product is sold.

13.6.2 For beverages containing glycyrrhizinic acid or its ammonium salt at

concentrations of 50mg/l or above, or of 300mg/l or above in the case of beverages
containing more than 1.2% by volume of alcohol, the statement „contains liquorice –
people suffering from hypertension should avoid excessive consumption‟
must appear after the list of ingredients. In the absence of a list of ingredients a
statement should appear near the name under which the product is sold.

13.7 Foods that have been irradiated must include a statement that the food has
been treated with ionising radiation. For example Treated with Ionising Radiation or
Irradiated (name of food).

13.7.1 When an irradiated product is used as an ingredient in another food, this shall be
so declared in the list of ingredients.

13.7.2 When a single ingredient product is prepared from a raw material which has
been irradiated, the label of the product shall contain a statement indicating the
treatment.

13.8 In the case of pre-packaged products „consisting‟ of or „containing‟ GMOs, the

words „genetically modified‟ or „produced from genetically modified
(name of the ingredient)‟ shall appear in the list of ingredients in parentheses
immediately following the ingredient concerned.

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