Review every ingredient behind “no added sugars”
This claim is about what was added and why, not simply the measured sugar total. Check sucrose, glucose, fructose, syrups, fruit-based ingredients, concentrates and compound preparations. Adding food for its sweetening properties can prevent the claim even if marketed as natural. Naturally occurring sugar does not automatically prohibit it.
If sugars naturally occur in the drink, the Annex requires the accompanying label indication “CONTAINS NATURALLY OCCURRING SUGARS.” A juice or coconut-water drink might qualify for “no added sugars” yet fail “sugars-free” because its naturally present sugars exceed 0.5 g/100 ml. Do not infer compliance from “100%,” “natural” or the front label.
Calculate fibre for the actual beverage
A prebiotic ingredient or inulin added to a sparkling drink does not by itself establish a high fibre claim. Confirm that the ingredient qualifies as fibre under the definition used by Regulation (EU) No 1169/2011, and substantiate the amount remaining in the finished product. Check supplier methods and processing losses.
Do not replace 100 g with 100 ml in the high-fibre threshold. The claim is expressed per 100 g or 100 kcal, whereas the beverage nutrition declaration generally uses 100 ml. If using the mass-based test, document product density or measured mass. If using the energy-based test, verify the correct final energy value. Review the per-100-kcal calculation carefully for low-energy drinks. Ingredient marketing sheets alone do not approve the label.
Make the nutrition panel and advertising consistent
Under Regulation (EU) No 1169/2011, most prepacked drinks need nutrition information including carbohydrates and sugars, expressed per 100 ml. Fibre is optional in the standard declaration, but Article 7 of Regulation 1924/2006 requires the amount of a nutrient subject to a nutrition claim to be declared. A high-fibre claim therefore needs a corresponding, substantiated fibre quantity on the nutrition information.
A sugar-free drink can contain authorised sweeteners, but that creates separate ingredient and labelling checks. Where applicable, Annex III of Regulation 1169/2011 requires a statement such as “with sweetener(s)” alongside the food name. Check authorisation and use conditions separately. “Prebiotic” language or a promise about digestion can amount to a health claim, which is not automatically permitted by qualifying for “high fibre.” See the Commission's claims framework.
Food information must be accurate and not misleading. Before printing, the responsible EU operator should check the destination country language and national rules. Claim requirements also apply to online listings and advertising.
Release artwork only after a claim-by-claim check
- Choose the exact wording and target EU country, including whether it implies a nutrition or health benefit.
- Collect the complete formula, ingredient specifications and each ingredient's technological purpose.
- Check finished-product data for sugars, fibre and energy in the units required by the chosen claim.
- Compare the claim with the Annex, then verify any sweetener restrictions and required accompanying text.
- Review the label and online copy together, including nutrition information, translated claims and the named EU operator.
- Record approval evidence for the specific formulation and artwork revision, and hold any claim that cannot be demonstrated.
Discuss EU-market beverage specifications with Nam Viet Group. Share the destination country, proposed claim, recipe brief and pack format so the manufacturing team can coordinate information for your importer's artwork review.
This guide addresses EU nutrition-claim screening, not Vietnamese export procedures or approval of a specific product, sweetener or health claim.
