Supplementary indications received a reprieve in 2007, and will now, subject to the Brexit deal negotiated with the EU, need to serve only the needs of the UK economy. Ronnie Cohen wonders where US influence is likely to lead us.

Supplementary indications are justified on the basis that they are necessary for trade with the United States and that if they were not permitted, a trade barrier would be created. This insistence on mutual acceptance of supplementary indications contrasts with the tolerance of different requirements for nutrition information and ingredients. Boxes of US and UK Pringles illustrate this inconsistency.

Common Supplementary Indications

Supplementary indications are additional non-metric units that can appear alongside metric units. These non-metric units are voluntary in the EU and mostly appear on products imported from the US. Dual labelling is still a legal requirement for goods regulated at federal level in the US under the Fair Packaging and Labelling Act.

As you can see from the image on the box of Pringles, the product weight is expressed in both ounces and grams. As a result of discussions between the European Commission and the US government in 2007, the EU agreed to extend the use of supplementary indications to support trade between Europe and the US.

Different Nutrition Information

However, let’s look at the differences in nutrition labelling for the UK and US markets. The differences reflect different legal requirements.

While there are some similarities between UK and US nutrition labelling, there are considerable differences. These differences are described here.

US nutrition information shows the following information:

Information in English and Spanish

Serving size in ounces and grams

Number of crisps per serving

Servings per container

Food energy in calories only

Food energy per serving only

Breakdown of total fats for saturated and trans fats

Amounts of cholesterol and sodium shown

Breakdown of total carbohydrates for dietary fibre and sugars

No salt figures given

Nutrition figures for amount per serving and % of daily value (based on a 2000 calorie diet)

Amount of protein shown

% daily values of Vitamin A, Vitamin C, calcium and iron

No allergen information is provided

Maximum daily intakes of total fat, saturated fat, cholesterol, sodium, total carbohydrates and dietary fibre are given for 2000 and 2500 calorie diets

UK nutrition information shows the following information:

Information in English only

Serving size in grams only

Number of crisps per serving

Servings per container

Food energy in kJ and calories

Food energy per 100 g and per serving

Breakdown of total fats for saturated fat only

No cholesterol or sodium figures given

Breakdown of total carbohydrates for fibre and protein

Amounts of salt shown

Nutrition figures for amount per serving and per 100 grams

No figures given for Vitamin A, Vitamin C, calcium and iron

Allergens are highlighted in capital letters (e.g. FIBRE)

No maximum daily intake information is provided

Different Ingredients Lists

Even though the UK and US ingredients lists look similar. there are some notable differences in the information provided. The British label provides allergen information (in this case, using capital letters), ingredients derived from genetically modified sources, E numbers (alongside descriptive names) and % of dried potatoes of the total contents. The American label provides none of this. Other differences in ingredients lists can be seen in the following table. Ingredients are listed in the order they appear on the labels.

US ingredients list UK ingredients list Dried Potatoes Vegetable Oil (contains one or more of the following: Corn Oil, Cottonseed Oil, Soybean Oil, and/or Sunflower Oil) Cornstarch Degerminated Yellow Corn Flour Rice Flour Maltodextrin Mono- and Diglycerides Contains 2% or less of salt Dextrose Monosodium Glutamate Whey Onion Powder Citric Acid Spices Natural and Artificial Flavours Autolysed Yeast Extract Tomato Powder Garlic Powder Torula Yeast Sugar Lactic Acid Sodium Diacetate Disodium Inosinate Disodium Guanylate Paprika Extract Wheat Dextrose Dried Potatoes (92.3%) Vegetable Oil (Corn* Oil, Cottonseed Oil, SOYA* bean Oil and Sunflower Oil) Corn* Starch Corn* Flour Rice Flour Maltodextrin Emulsifier: Mono- and diglycerides of fatty acids (E471) Salt Dextrose Flavour Enhancer: Monosodium Glutamate (E624), Disodium Inosinate (E631) and Disodium Guanylate (E627) Whey (MILK) Onion Powder Acidity Regulator: Citric Acid (E330), Lactic Acid (E270) and Sodium Diacetate (E262) Spice Natural and Artificial Flavouring Autolysed Yeast Extract Tomato Powder Garlic Powder Torula Yeast Sugar Paprika Extract WHEAT Dextrose

On the British label, whole words written in capitals warn about allergens and words marked with * indicate that the ingredient is derived from a genetically modified source.

I leave you to spot other differences in these lists.

Other Labelling Differences

Other differences in the labels including format and layout, spelling differences (e.g. for words such as “flavour”, etc.), importer information and best before date.

Supplementary Indications and Labelling Issues

A large number of differences in product labelling regulations exist between the United States and the European Union. The way that European importers solve this problem is to stick a label over the section with US nutrition and ingredients lists to conform with EU regulations. However, the British repeatedly argued that the abolition of supplementary indications would create a trade barrier between the US and the EU until they were permitted indefinitely in 2007. Why are potential differences in the use of supplementary indications seen as a trade barrier whereas other differences in labelling regulations are not? Surely, a sticker can overcome not just one problem, but both.

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