Clean labels vs health claims – Can both work together?


Keller and Heckman LLP, Brussels, Belgium


In the current context of increasing demand from consumers for transparency and simplicity in labelling, health claims and so-called clean labels have started to gain prominence amongst food manufacturers. 

While health claims are strictly regulated, the term “clean label” is not defined anywhere in the legislation. Clean labelling is a growing trend associated with the use of simple ingredient lists describing a product as minimally processed and free from additives. A recent research showed that, products that position themselves as natural or free from additives were higher ranked by consumers than products with health claims.

The article provides insight into the elements of the term clean label from the regulatory perspective and looks into the reasons why manufacturers give preference to clean labelling rather than using health claims on their products.


Nowadays, EU consumers are more and more concerned about the food composition and in particular about the presence of undesirable ingredients.  There is an increasing demand for more transparency and simplicity in the labelling of food products. Consequently, many manufacturers in the food industry opted for a reformulation of their products or placing food products on the market that are better corresponding to the new trends in consumer choices. The beneficial aspects of these foods are generally communicated to the consumers through food labels and advertising. The regulators support the industry initiatives of promoting healthier diets, but at the same time they realise the necessity to protect consumers against false or misleading messages from the food manufacturers regarding their products. All this led to the establishment of a current nutrition-related set of policies and legislation. A key rule is envisaged by the Food Information to Consumers Regulation (EC) No 1169/2011 (‘FIC Regulation’), which states that a food label should not mislead consumers regarding to the characteristic ...