On October 13, corrections were published that contribute to ensuring clarity, objectivity, and consistency of the Resolution of the Collegiate Board of Directors (RCBD) [Resolução da Diretoria Colegiada – RDC] 429/2020 and Normative Instruction 75/2020. In the meantime, the General Management of Food (Gerência-Geral de Alimentos – GGALI) clarifies that, for labels already prepared, the respective corrections will not have relevant impacts.
However, if there are already labels prepared improperly, with regard to the corrections made, the disposal of these packages can be done by the manufacturers, provided that they comply with the administrative procedures for depleting their stock with the packaging in disagreement, according to the guidelines contained in Technical Report 55/2014 or normative act that deals with the subject.
Which devices were corrected?
The first item of the list of corrections tried to correct an error in the writing of the term “dietary fiber”, with the term used in the singular (dietary fiber) instead of the plural (dietary fiber) which is correct, since this nutrient covers a set of substances with different chemical structures. [* In Portuguese the word ‘fibra = fiber’ receives an ‘s’ at the end when it’s plural*].
Another item was an error in the PostScript point definition regarding the measurement equivalence in inches, which was corrected from 0.33 millimeters to 1/72 inch. It was also identified that the portions indicated, for the most part, were published without the relative unit of weight (g) or volume (ml) to be observed. Still in this area, the portions of eggs, soy-based sauces and sauces based on dairy products or broths were published incompletely, without explaining that the portion must correspond to the amount needed for the established homemade measure.
Corrections in different models.
Now dealing with the vertical model, the terms “Total carbohydrates” and “Dietary fiber” were corrected to “Carbohydrates” and “Dietary fiber” (*Plural variation in Portuguese). The word “portions” was incorrectly included after “Portions per pack: 000“. In the horizontal model, the title “NUTRITIONAL INFORMATION” was centered instead of the left alignment, and the term “Saturated fats” was corrected, staying at the same indentation level as “total fats”.
In the broken vertical model, the word “portions” was removed after “Portions per pack: 000“, and, in the broken horizontal model, the title “NUTRITIONAL INFORMATION” was centered to maintain the standard, as well as the title “NUTRITIONAL INFORMATION” of the aggregate model. The reference to “(homemade measure)” after “Portion: 000 ml” was excluded and the term “Saturated fats” was published at the same indentation level as “total fats”.
Typography corrections.
Regarding the typography, the title “NUTRITIONAL INFORMATION”, the centered vertical alignment was included, and in the subtitles “Portions per package:” and “Portion: Xg or ml (homemade measure)”, it was corrected for the alignment to be centered and the alignment vertical for the horizontal, horizontal broken, aggregated, centered, vertical and vertical broken models. In the headings of the columns “100g”, “Xg or ml” and “%VD*”, it was changed to bold style and in the nutritional values of reduced format, the correct is the body of 6 pt.
Regarding the footnotes, there is now an indication of superior vertical alignment in the terms “*Percentage of daily values provided by the portion.” and “**In ready-to-eat food.” The acronym “%VC” was corrected to “%VD”, the unit “g” for sodium to “mg”, the misspelled term “Açúcares adcionados” was corrected to “Açucares adicionados (Sugars added)”, as well as “indentation” for the correct term “indentation” and %DV for total sugars.
An inconsistency was also identified in item 2 regarding the requirements for horizontal alignment of the typography of the information block “Alto em (High in)”, which should be started at a 2Y distance from the right edge instead of a 2Z distance from the right side of the information block, as per models presented in Annex XVII of IN No. 75/2020, as well as in the constructive mesh available on the Anvisa portal.
Finally, grammatical errors were identified in the labeling criteria for the attributes “does not contain sugars” and “does not contain total fats” and in the composition criteria for the attribute “no added fats”, contained in items 2 and 4 of Annex XX of IN No. 75/2020.