Summary:
This resolution regulates nutritional claims and front-of-pack nutritional labeling (FOPL) of pre-packaged food in Brazil.
Description:
Context of adopting front-of-pack nutritional labeling (FOPL) in Brazil
In Brazil, the National Health Surveillance Agency [Agência Nacional de Segurança Sanitária – ANVISA], an independent government body, adopted the FOPL resolution through a regulatory process initiated in 2017. This process was among the first in the country to incorporate a regulatory impact assessment (in Portuguese, “Análise de Impacto Regulatório”).
ANVISA approved the final text in October 2020, with implementation set for October 2022, except for reusable packaging such as soft drinks, which was scheduled for October 2025. However, ANVISA postponed the obligation to implement the regulation by one year. As a result, civil society filed a lawsuit against ANVISA to prevent further delays in the resolution’s implementation.
Highlights of the resolution
This document applies to pre-packaged foods, including beverages, food additives, technology adjuvants, and foods intended exclusively for industrial processing or food services (Article 4). Specifically, it outlines the mandatory nutritional information that must appear on both the back-of-pack and front-of-pack nutritional labeling (FOPL) in Brazil.
Among the various definitions in the resolution, the definition of front-of-pack labeling is especially important. In particular, the document defines it as “any declaration intended to inform the consumer about the nutritional properties of the food, including the nutritional information table, front-of-pack labeling, and nutritional claims” (Article 3, XXXI).
With regard to the FOPL regulation (Articles 18-23), the normative clearly states that the magnifying glass serves as the warning symbol for FOPL. Moreover, the resolution mandates the use of the claim “high in” to alert consumers to the excessive presence of critical nutrients. Consequently, this policy is strictly required on products where the amounts of added sugar, saturated fats, or sodium are equal to or greater than the limits defined in Annex XV of Normative Instruction No. 75 of 2020.