Good day. I produce vegetable salads. Packaged, mainly delivered to stores, but also to canteens. Up until now, I have only provided the ingredients and other things regarding shelf life and the manufacturer on the label. We have never counted the nutritional value because there was no such obligation. However, my wholesale customers, and indirectly their customers, i.e. retail chains, have set conditions since the beginning of the year that I must have packaging in accordance with the new regulations or we will lose the shelf. They are putting more and more pressure, so I have to sort it out quickly. However, a problem has arisen and I do not know what to do next.

The sanitary inspectorate replied that it is none of their business that I should report to the National Food and Nutrition Institute. After many unanswered calls, I sent an email, they replied in general that everything is in the regulation and I should accept average values. The problem is, however, that there is no such explanation in the regulations, namely - our raw materials have different nutritional values ​​at different times of the year.

We sent a few to the laboratory and each time the values ​​were different, even though they were the same varieties from the same field and grown in the same way. Cabbage, beetroot, carrot, celery, etc. tested in autumn and spring have completely different values. The results we received are not even the same as those in the National Food and Nutrition Institute tables, they are similar, but not the same. Contrary to popular opinion, in spring, even though after winter storage some values ​​are higher than in autumn after harvest. The conclusions were very simple, that in spring there are more nutritional values ​​and vitamins per 100g because water evaporated during winter storage and the value remained, now there is simply more of it per 100g.

That is why we have a dilemma - how to calculate nutritional values? Which results should be included on the label so that during the inspection of the information's compliance with the product we do not get a penalty for non-compliance. How are we supposed to defend our results during the inspection? Please reply if you know anything about it.

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EXPERT ANSWER:

You have described a complex problem, but we could fit the answer into one sentence – Average values ​​should be used.

However, we suspect that such a short answer to such a complex problem will not be satisfactory, so we will develop the answer to each doubt in turn.

First of all – your company's situation was foreseen by the European Parliament, or at least the regulation that precisely indicates the method of calculating nutritional values ​​precisely defines which values ​​should be provided on the packaging to the consumer.
Namely, REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (EU) NO. 1169/2011 [SECTION 3. Nutritional information. Article 31. Calculation. Point 4], states:

The values ​​provided, as appropriate for the given case, are average values ​​based on:

a) the analysis of the food carried out by the manufacturer;

b) calculation based on known or actual average values ​​of the ingredients used; or

c) calculation based on generally available and accepted data.

And on this basis, we answer your questions with one sentence at the beginning. The Regulation mentions average values. And it is these average values ​​that you are obliged to provide on the label. So there is no point in wondering whether it is appropriate to provide the values ​​from autumn or spring, but to take the average of both results. By examining the situation of your plant in detail, we will answer that in principle you should add up all the nutritional values ​​that you know for your raw materials, i.e. those from spring, and those from autumn, and maybe even others that you know, and only then take the average. This will be a calculation in accordance with point b) of the Regulation, i.e. a calculation based on the actual average values ​​of the ingredients used. Actual, i.e. obtained in the form of laboratory analyses. This is a good way to calculate nutritional values, but probably the most expensive possible. How to do it just as well, and definitely cheaper? Your raw materials, such as those mentioned in the question – cabbage, beetroot, carrot, celery, etc. other vegetables, are common raw materials, whose nutritional data, including minerals and vitamins, are known as generally available and accepted data, for example in the Raw Materials Catalog of the FOODCAL Nutrition Value Calculator program. Calculation with the FOODCAL Calculator program qualifies for up to two of the methods listed in the Regulation, i.e.:
– calculation based on known average values ​​of the ingredients used (b)
– calculation based on generally available and accepted data (c)

I would like to add that the data assigned to raw materials in the Raw Materials Catalog of the FOODCAL Calculator are presented based on data from the most well-known and authoritative, trustworthy data, coming from institutes such as the National Food and Nutrition Institute, the Danish Food Composition Databank, the United States Department of Agriculture, the National Nutrient Database for Standard Reference and specifications directly from raw material suppliers who performed laboratory analyses. Each raw material has a description that provides the source. This is also visible in the printouts of the calculation reports that the program allows, and it will be very useful in the event of an inspection.

We hope that your doubts have been dispelled. We invite you to use our software, and in case of further questions, we will be happy to help.

Editorial Team
Nutrition Calculator FOODCAL
https://pl.nutrition-calculator.com

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