Professional Documents
Culture Documents
397
003/
2005
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ISSN 0250-5118
FIL/IDF
CONTENTS
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397/2005
10
Disclaimer
10
1. Background
11
2. Introduction
11
12
12
6. Denitions
7. General principles
6
6
8.7.2 Recombination/reconstitution
13
14
14
14
15
10
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16
Disclaimer
The content of this paper does not replace the Codex General Standard for the Use of Dairy
Terms (CODEX STAN 206) (or GSUDT), does not provide a legal opinion on its use and is
therefore not intended for application within the context of the WTO Agreement on Technical Barriers to Trade.
The purpose of this paper is to provide the reader of CODEX STAN 206 with information
on the nature, intent and possible implications of the GSUDT, recognizing that practical
interpretation of the individual provisions of the standard must be done within the context
of the individual national situation and traditions, including the framework of the national
legislation of the country, and consequently is likely to vary from country to country.
Abbreviations
CAC - Codex Alimentarius Commission
CCMMP - Codex Committee on Milk and Milk Products
FAO - Food and agriculture Organization of the U N
GSLPF - General Standard for the Labelling of the Pre-packaged Food
GSUDT - General Standard for the Use of Dairy Terms
WHO - World Health Organization
WTO - World Trade Organization
1. Background
Since the invention of articial butter, many developments in food technology have striven to obtain similar sensory qualities to those of a number of milk products using a variety
of raw materials other than those derived from milk.
Milk and milk products have a high nutritional value, unique functional properties and
a very positive sensory image and appeal. In consequence, milk products have achieved
a signicant market position and share of household consumption in many homes, in particular in countries where consumption of dairy products is a tradition, and nowadays in
many others. This position makes cheaper imitations very lucrative and consequently it is
tempting to take advantage of misleading practices. In the course of recent years this fact
is mirrored in the number and nature of practices that occur and that could be considered
as misleading in a number of countries, depending on the local context.
The GSUDT was developed in order to clarify and provide guidance on the correct use
of terms that are universally identied with dairy products so consumers around the world
will have a clear understanding of the type of product they are purchasing and consuming.
This is important both in countries where consumers are familiar with dairy products by
tradition and in countries where they are not.
2. Introduction
For 45 years the Codex Code of Principles concerning Milk and Milk Products provided a
framework for the identity of milk and milk products. This Code played an important role
in avoiding confusion between dairy products and non-dairy foods, including imitations of
and substitutions for milk products. In this role the Code was a tool for the protection of
consumers against misleading practices and fraud.
2
The Code was elaborated in 1958 by FAO and WHO and was the very rst international food
standard text. During its time of existence, 73 countries formally accepted the Code and
the principles laid down in it were implemented in the national legislation of many countries
and regions.
In 1994, the 1st session of the newly established Codex Committee on Milk and Milk
Products (CCMMP) decided to initiate a thorough revision of the old Code. The reasons for
this were evident, as there was a need for:
Aligning the content with the General Principles of Codex and generic Codex texts following the restructuring of the former Joint FAO/WHO Committee of Government Experts on
the Code of Principles concerning Milk and Milk Products into a regular Codex Committee
(the CCMMP);
Removing optional clauses and unnecessary details and improving the scientic basis to
comply with the general policy adopted by the Codex Alimentarius Commission (CAC)
following an international conference in 1991 (FAO/WHO Conference on Food Standards,
Chemicals in Food and Food Trade Melbourne (conclusions from the conference can be
found in Appendix 4 to ALINORM 91/40 1991 Report of the 19th session of the CAC, 110 July 1991);
Removing provisions that duplicated other Codex provisions; and
Removing the biased differentiation between cows milk and milk from other animal species (for example, buffaloes milk).
The revision was nalized in 1997 at the 3rd session of the CCMMP as a Draft General
Standard for the Use of Dairy Terms. The Codex Alimentarius Commission nally adopted
the draft in June 1999 as Codex Standard 206. The name of the Standard is often abbreviated to GSUDT and is reproduced in Annex 1.
It should also be noted that the TBT Agreement provides individual countries with sufcient
opportunities to justify appropriate labelling requirements, independent of the existence
of a Codex reference text, when the local conditions in individual countries can provide
the necessary justication (a Legitimate Objective) to deviate from a Codex text. The
provision of a Codex standard merely serves the purpose of making it easier for a country
to justify its technical regulations where it chooses to follow the Codex standards. Compliance with Codex texts such as the GSUDT does not automatically give free access to any
country. Access depends on whether the importing country has identied additional or
different national legislation supported by other legitimate objectives; however, a country
may nevertheless choose to allow free access. In all cases, it is the requirements of the
importing country that shall be met.
6. Denitions
The GSUDT denes the basic plain dairy products milk, milk product, recombined milk
product, reconstituted milk product, and composite milk products.
3 The scope of the GSUDT is not restricted to product labelling.Thus, the provisions of GSUDT may equally be
applied to promotional activities such as advertisements and other marketing activities.
4 Recently established standards of identity for milk products have been drafted incorporating references to the
GSUDT. Older standards were produced under the umbrella of the former Code of Principles. This approach has
enabled the drafting of relatively simple standards.
Milk is dened as the normal mammary secretion of a milking animal (or animals) obtained from one or more milkings without either addition to or extraction from it, intended
for consumption as liquid milk or for further processing.
When read in conjunction with other sections of the GSUDT, this denition is a denition for raw milk. Liquid milk that has been subjected to a treatment is classied as a milk
product. However, the term milk is widely used as the designation for whole drinking
milk although it has been subjected to certain treatments. It is therefore necessary to
specify additional provisions that allow for the continued use of the term milk in the naming of these products (see 8.2 of this paper).
The mammary secretion of any mammal that is subjected to milking is covered by
the denition. Such animals currently include cows, ewes, goats, buffaloes, camels, yaks,
zebu, reindeer, llamas, mares, etc. It is important to keep this denition in mind because
most milk product standards state that the product can be made from milk as understood
by this denition.
Milk product is dened as a product obtained by any processing of milk, which may
contain food additives, and other ingredients functionally necessary for the processing.
Although a milk product shall be made from milk, the denition does not hinder the milk
from being subjected to various processing steps before it becomes an end product.
The other ingredients functionally necessary for the milk product and/or its manufacturing process include food additives, processing aids, and other ingredients, which in the
manufacturing process are functionally necessary, such as (but not limited to) salt, gelatine
and starch. The addition of a substance such as gelatine in excess of what is functionally
necessary is regarded to be a replacement of milk constituents and will result in that product not being a milk product and subject to the provisions in Section 4.6.3 of the GSUDT
(non-dairy food).
Other additions such as avouring substances, including spices, sweeteners and avours, are not functionally necessary for the manufacture of a milk product. When added,
and provided that they do not replace milk constituents in whole or in part, the milk product is classied as a composite milk product (see 6.2 of this paper). However, in some
cases, non-dairy substances, which in the context of other milk products are considered as
avouring substances, are functionally necessary and are included as part of the technical
denition of a milk product. One example is sugar in Sweetened Condensed Milk, added for
the purpose of preservation of the product (and not to sweeten it).
The GSUDT also includes denitions for recombined and reconstituted milk products.
These terms are needed for dairy products meeting the requirements of GSUDT Section
4.4 - Use of terms for reconstituted and recombined milk products (see 8.7.2 of this
paper).
A composite milk product is a product composed of a milk product and other food(s),
where the milk constituents are an essential part in terms of quantity of the nal product.
This denition hinges on what is understood to be essential in terms of quantity in the
nal product and is usually dependent on a number of factors, such as:
- the need to characterize the dairy product for the nal consumer or user,
- the nature of the milk product (for example, dry matter content, avour intensity)
- the nature of the added food (for example, dry matter content, avour intensity)
As the non-milk constituents should not, in whole or in part, take the place of any milk
constituent, other foods and substances that are acceptable include those that provide
additional characteristics to the dairy product, such as avouring foods, spices, avours,
water etc.
Where a non-dairy component is added with the intention of replacing milk constituents
(for example, milk fat, milk protein), the use of dairy terms for the resulting food is regulated by Section 4.6 of the GSUDT (see 9 of this paper)5.
7. General principles
One of the fundamental principles of the Codex General Standard for the Labelling of Prepackaged Foods (GSLPF) is that food shall be described and presented in such a manner as
to ensure that consumers are not misled or confused. No labelling shall be false, misleading, deceptive, or create an erroneous impression regarding its character in any respect,
including being suggestive of any other product with which the food might be confused.
The statement above is the foundation of many of the provisions of the GSUDT, including the general principle in Section 3, which emphasizes the general objective of the Codex
Alimentarius to ensure that consumers are not misled, that is, fair practices in food trade.
The provision is specically needed in the GSUDT to ensure that the principle also applies
to non-prepackaged foods.
Section 4.1.1 of the GSUDT reinforces the naming provisions of the GSLPF.
According to Section 4.1.1 of the GSLPF, the name of any food shall indicate the true
nature and shall normally be specic and not generic.
The name applicable to a food shall be chosen using the following hierarchy:
1. The rst priority shall be the name established by Codex. If there is a Codex Standard
established which species the name of the food, this name shall be used8.
2. Where a Codex standard has not been established, the name prescribed by national
legislation applies. (In this case, the same product may be named differently in different countries).
3. Where no Codex standard exists and if national legislation does not stipulate the
name, the name shall be chosen from among the two options below:
- a common or usual name existing by common usage; or
- an appropriate descriptive term that is not misleading or confusing to the consumer.
The provisions of the GSUDT apply to all three levels of the above hierarchy.
5 Sweetened condensed milk (CODEX STAN A-4) is a milk product, not a composite milk product, whereas
sweetened fermented milk (CODEX STAN A-11) is a composite milk product.
6 The term horizontal provision means a provision that is applicable to (all) foods in general.
7 Codex General Standard for the Labelling of Prepackaged Foods (CODEX STAN 1-1985, Rev.-2001)
8 Standards of identity have been established for many milk products; however, these standards do not mandate
the use of the names they contain but specify the technical criteria and conditions that should be observed when
the names are used.
Section 4.2.1 of the GSUDT stipulates that only foods complying with the denition for milk
may be named milk (that is, without qualication).
Note: Sections 4.2.2 and 4.2.3 of the GSUDT allow, and provide the conditions, for
the use of term milk in the naming of certain milk products (see 8.5 and 8.8.1 of this
paper).
However, it is further stated, that the qualier raw should be added to the name where
milk is sold as such (that is, not processed in any way). This requirement is necessary,
as the general labelling rules (Section 4.1.2 of the GSLPF) do not require such additional
wording because the nature of the prepackaged milk is not changed, as it has not received any further processing ( (see also 8.5 of this paper on the naming of modied
dairy products). This statement has no labelling consequences for raw milk used for processing but it does have for raw milk sold in bulk and sold for direct consumption.
Section 4.3.1 of the GSUDT states that the names specied in the Codex identity standards for milk products may be used only if the product complies with the corresponding
standard.
This provision is needed for the correct understanding of the subsequent provisions and
for consistency with the format of Section 4.2 of the GSUDT.
Products that, for whatever reason, do not fall under the scope of one or more of the existing standards (Codex or national), shall be designated by appropriate non-misleading
names, either the common or usual name (existing by common usage) or an appropriate
descriptive term that is not misleading or confusing to the consumer. Competent authorities do not provide the specic designations of such products and in consequence it is typically the manufacturer and/or packer who identify them.
The only option available to the manufacturers of such products is often a descriptive
designation, as commonly used names may not have been established.
The principles of the GSUDT apply equally to these products, including those relating to
compositional modication and naming of composite milk products9.
In order to prevent misleading the consumer, Section 4.1.2 of the GSLPF states the
conditional obligation to use appropriate descriptors in addition to the name. It reads:
There shall appear on the label either in conjunction with, or in close proximity to, the
name of the food, such additional words or phrases as necessary to avoid misleading or
confusing the consumer in regard to the true nature and physical condition of the food including but not limited to the type of packing medium, style, and the condition or type of
9 The GSUDT does not provide specic regulation of the use of names established by competent authorities when
these are used in descriptive naming constructs that include established names of other milk products. Nevertheless the standard does provide rules in this respect for non-dairy products (Sections 4.6.3 and 4.6.4 of the
GSUDT), where the use of milk product names is allowed only if the non-dairy food does actually contain the milk
product in question as an ingredient. Reference to the same dairy product name that is the subject of imitation is
not allowed, for example vegetable cheese.
According to Section 4.5 of the GSUDT, composite milk products shall be named by using
the name of the milk product constituting the essential part together with a description of
the other characterizing ingredients added (such as avouring foods) given in close proximity. The description of the other ingredients may be simplied by, for instance, using a
group name.
Some examples are strawberry yoghurt, chocolate milk, spiced cheese, garlic
butter, vanilla ice cream.
The GSUDT specically regulates two types of modications related to the raw materials used.
Section 4.1.2 stipulates the conditional requirement to declare the animal of origin of the
milk (or milk products) used in the manufacture of the milk product.
The provision ensures compliance with Section 4.1.2 of the GSLPF as the origin of the
milk used may inuence the nature of dairy products, such as in regard of avour, colour,
texture, composition, etc. Labelling is required only where consumers might be misled by
the omission. Therefore, the labelling may not be necessary to the extent that consumers
anticipate a certain origin (for example, cows milk in Scandinavia/US; a mixture of cows/
buffaloes milk in India; a mixture of various kinds of milk in some African countries).
Other means to address the same issue can be considered as an alternative to labelling,
where required, including reserving a specic variety name for a product made from milk
of (a) particular animal origin(s) or, conversely, specically associating such a name for a
product made from milk of any animal species.
As the principle applies to all milk products, the main reason for inserting this provision
in the GSUDT was simplication - all milk product standards of identity would otherwise
need to include the same provision.
10 The naming consequences of some modications of milk products are specically addressed by the GSUDT.
This concerns certain raw material modications (see 8.7 of this paper) and compositional modication (see
8.8 of this paper).
Corresponding
reference
The product
made from cows milk
Nature
Modied mineral
content
Demineralized
Modied lactose
content
Lactose free
Fat fractionation
Spreadable
Modication of fat
content
Partly skimmed
Cream....
Dried
Spreadable
Drinkable
Addition of micronutrients
Calcium enriched
Fat reduction
Light
Fruit....
Plain version
Spiced....
Plain version
Tangy
Traditional version of
yoghurt
Mild
Traditional version of
yoghurt
Change of water
content
A change in
nutritional properties
A compositional
modication
Example of
descriptors
Flavoured
A change in sensory
properties
Different technology
Sterilized
Extended shelf life
Microbiocidal
treatment
UHT
Pasteurized version
Long life....
Made more soluble
A change of physical
condition
Instant
Shredded
Sliced
Non-instant version
Whole version
8.7.2 Recombination/reconstitution
Section 4.4 of the GSUDT addresses the need to declare the fact of recombination and
reconstitution of milk products. This provision is also in compliance with Section 4.1.2 of
the GSLPF.
The normal situation is that recombination and reconstitution techniques need not be
indicated on the label. The rationale for this is that most of the milk product standards of
identity permit the use of any milk product as raw material, thus allowing reconstitution as
well as recombination without any restriction.
The recommendation is based on the premise that with most products it would not be
necessary to use the descriptors recombination or reconstitution for the followingreasons:
The raw materials are listed in the ingredients list.
Most milk products are subjected to a number of different treatments and processes11.
However, in certain countries or for specic products where the lack of a statement of
reconstitution or recombination is considered misleading to the consumer, the provision
includes a wording that enables the authorities in such countries to request labelling and/or
allows for the inclusion of such requirement in relevant product standards.
The GSLPF requires the use of appropriate descriptors when a food is modied. Application of this principle with respect to compositional modication is further elaborated in the
GSUDT (Sections 4.2.2, 4.2.3 and 4.3.3, respectively). It should be emphasized that, notwithstanding the provisions of these sections of the GSUDT, the general provisions of the
GSLPF apply to all other (non-compositional) modications made to the milk product.
As the GSUDT is not a compositional standard, in general it does not prohibit or require
any particular composition or method of manufacture12. It is concerned only with the correct naming of the products (whatever they may be). Consequently, Section 4.2.2 addresses the requirements for use of the term milk as such, whereas Section 4.2.3 addresses
the naming of any milk product, modied or not, made from raw milk or milk products13.
The general provision in Section 4.2.2 of the GSUDT regulates the conditional use of the
term milk in the naming of milk that has been modied in composition. It is beyond the
scope of the GSUDT to address the kinds of modications that should be allowed.
As no Codex standard exists for drinking milk, any restrictions (in composition and
processing) on this milk product are left to national jurisdiction. The GSUDT requires only
that the name of milk, the composition of which has been changed, may only include the
term milk if the modication made is clearly stated in close proximity to it.
Some examples of names of compositionally modied drinking milks that would be allowed in conformity with the GSUDT:
* Skim milk
* Lactose reduced milk
* Vitamin fortied milk
* Protein enriched milk
* Calcium enriched milk
11 The consumer would normally not be misled by the use of the common name without specic indication of the
fact of recombination or reconstitution in the name of the food. Adequate information on the raw materials used
is provided in the ingredients list. This approach has been chosen for most other foods as well.
12 One exception is the provision in Section 4.2.3 of GSUDT concerning suitable technology for protein and fat
adjustment.
13 The GSUDT may seem unclear on this point, as the naming of the milk product drinking milk is addressed in
the Section 4.2.2 dealing with the use of the term milk. Nevertheless, this minor deviation from logic does not
change the meaning.
10
Similar to the provision governing compositionally modied milk (Section 4.2.2) Section
4.3.3 of GSUDT regulates the use of the names of milk products that have been modied
in composition. For the purpose of this provision, a compositionally modied milk product
is a milk product altered in composition compared to the reference product14.
The name of a milk product should only be used if the following three conditions are
fullled:
1. A clear description of the modication to which the milk product has been subjected appears in association with the name;
2. The essential product characteristics are maintained; and
3. The product complies with the limits of modication detailed in the standard(s) concerned, as appropriate.
These provisions have two objectives:
1. To emphasize the principle that a milk product differing from the reference (normal,
usual, original, predominant) version shall be named with a qualier in association to
the name of the food. This principle is in conformity with Section 4.1.2 of the GSLPF.
2. To emphasize the principle that there are limitations to the extent that modications
can be made without altering the main characteristics (basic identity) of the reference
product. This principle is important in order not to mislead consumers with regard to
the nature (identity) of the product and to ensure fair trade practices. The following examples of naming illustrate some extremes which are not acceptable and which would
not be allowed according to the provision:
fat-free butter, as the main characteristic of butter is milk fat.
low fat cream (below 1.5 % fat as provided for in nutritional claims regulations), as
the main characteristic of cream is a higher milk fat content than milk.
protein free cheese, as the main characteristic of cheese is coagulated milk protein.
Many individual standards of identity for milk products specify the limits for compositional modications. Examples include:
Butter15:
Preserved milk products:
Individual cheese varieties:
Creams/Prepared Creams:
Fermented Milks:
Concentrated Fermented Milks:
Whey powder:
Alteration of the composition of the milk used for manufacturing is a normal processing
tool to control end product composition. Such alterations may be relatively small (adjustment) or substantial (modication). Many milk products are subject to adjustment of the
main constituents prior to, or during manufacturing (fat, protein, dry matter, lactose, and/
or fat-free dry matter). For instance, the fat and/or protein content of cheese milk may
14 A compositional reference product is the normal, usual, original and/or predominant version of the product
that is named with the name unqualied (e.g. Cheddar, Whole milk powder, Whey powder). In some Codex
standards for milk products, the reference composition is specied, directly or indirectly; in others such differentiation is not incorporated. In the most recent milk product standards (in Section 3.3 of all individual milk product
standards), a statement has been inserted that species which compositional modication is considered in compliance with Section 4.3.3 of the GSUDT.
15 A new standard for dairy spreads that allows fat content modications below 80% is currently being developed by Codex
11
be adjusted to meet the compositional requirements of full (reference) fat versions of the
cheese and/or to compensate for seasonal variations in milk composition.
The GSUDT addresses the common compositional adjustments of drinking milk, both
the well-established adjustment of milk fat content and the less common adjustment
of protein content. This was found necessary bearing in mind that national legislation in some countries already has provision for protein adjustment of drinking milk or
may introduce it in the future and to take the impact on national legislation of the TBT
Agreement into account. The objectives of providing for compositional adjustments in
this way are as follows.
to allow individual countries to retain sovereignty16 in permitting and regulating such
practices, and
to ensure that the processing methods applied do not alter the whey protein to casein
ratio (the use of ultraltration and/or lactose addition do not alter this ratio)
The former Code of Principles did not stipulate a requirement to declare the fact of
fat adjustment17 and this recommendation was followed in many countries. As the GMP
technology involved in protein adjustment is very similar to fat adjustment (separation
combined with partial re-mixing), it might have been expected that the same principle
would have been extended to protein adjustment as well. However, this was not acceptable to many countries and, as a result, it was decided that the fact of fat adjustment
and of protein adjustment shall be declared in accordance with the provisions for the
naming of milk modied in composition deemed appropriate in the country of retail sale
(Section 4.2.3 of GSUDT).
8.9.2 Processing milk for milk products other than drinking milk (Section
4.3.2 of GSUDT)
For some decades, the fact of fat and/or protein adjustment has not been declared in
the labelling of certain milk products. This is illustrated by the following examples:
The fat content of cheese milk is often adjusted to meet the compositional requirements of full fat versions of the cheese. The fact of such adjustment need not be
declared and, consequently, is normally not required by national legislation.
The fact of protein adjustment or the adjustment of the fat-free dry matter content of
milk used in the manufacture of cheese and fermented milks, (for example, by membrane ltration or evaporation), to meet the compositional requirements (minimum
dry matter contents) or for functional purposes, need not be declared according to
any typical national legislation.
The provision in Section 4.3.2 of the GSUDT is intended to avoid any lack of clarity
with regard to the labelling of the fact of fat and/or protein adjustments of dairy products in general (that is, within the limits laid down in the corresponding standards of
identity). However, fat and protein modications (that is, beyond the reference limits)
trigger labelling and are addressed in Section 4.3.3 of the GSUDT (see 8.8 of this
paper).
Except for the preserved milk products (CODEX STANs A-3, A-4 and 207), current
Codex identity standards do not restrict protein and fat adjustment of the milk used as
long as the composition of the end product complies with the standard in question.
16 Without such a provision, the TBT Agreement will make it more difcult for a country to enforce restrictive
domestically applicable rules against imported products. The existence of the provisions in a Codex Standard,
because of its international recognition as a reference, makes it more legal for a country to take its own decision
and makes it mandatory for exporters to respect the legislation of the importing country. The provision therefore
assists individual countries in justifying country specic approaches.
17 Within this context, adjustment means minor changes in composition within natural variation, whereas compositional modication means compositional modication beyond natural variation.
12
The general principle laid down in the GSUDT is that dairy terms are reserved to milk and
milk products. However, owing to established non-misleading common practices, there is
a need to make some specic exemptions from this general principle as well as to specify
under which conditions and to what extent dairy terms may be used for other foods.
Examples of possible misleading use of dairy names and terms
Misuses of designations:
the name butter, vegetable butter and butter blend for fat spreads containing
vegetable oil
the designations vegetable oil cheese, rice cheese and margarine cheese
the margarine names rama, edelram, butella, beurrine and cremex (according
to the language in the country of sale)
the name coffee creamers for coffee whiteners without milkfat
the names soy milk and soy yoghurt for soy-based products
Descriptions of the use or the functionality:
the claim made exactly like butter
the claim real alternative to cream
General presentation of products:
pictures of cows, churns, milk cans, etc. on the package of non-milk products
It should be emphasized, however, that in evaluating whether a specic labelling or
marketing practice is misleading, consideration must be given to the overall context in
which the particular information (claim, representation) is put.
Names for certain non-milk products which, owing to long established practice, include
dairy terms are recognized and allowed by the GSUDT, provided that the exact nature of
the product is clear to the purchaser from its long established usage18 or when the name is
clearly used to describe a characteristic quality of the product.
18 Although the GSUDT uses the term traditional, this term is not used in this document, mainly because the
term is not dened internationally. The interpretation of its meaning is left to national jurisdiction and may therefore vary from country to country.
13
The GSUDT does not include a complete list of such commonly recognized names. Which
dairy terms are permitted in the naming of non-milk products therefore depends on national interpretation.
In Codex, a list of accepted names for non-milk products that include dairy terms does
not exist. However, some Codex standards for various non-milk products contain the following names:
Coconut milk
Coconut cream
Skimmed coconut milk
Cocoa Butter
Cow peas
Milk chocolate
It should be noted that for these products it is commonly accepted that the use of dairy
terms in the product names is a long established practice.
Many countries have established lists of names for non-milk products that include dairy
terms. These nationally recognized names apply on their domestic markets only. However,
it would seem not be in compliance with the GSUDT to permit the use of representation
referring to dairy terms in the labelling or promotion of these products.
The rules for the other non-milk products are based on a few key understandings and an
overview is provided below.
In general, no label, commercial document, publicity material or any form of point of sale
presentation may be used which claims, implies or suggests that the product is milk, a milk
product or a composite milk product, or which refers to one or more of these products (for
instance by using adjectival comparisons between milk products and non-milk products
such as -like, -type).
Apart from the mandatory ingredient listing of the milk ingredients used, opportunities for
using dairy terms in the labelling and marketing of foods containing milk ingredients will
be governed by the following, whether or not milk or milk products constitute the essential
part and whether or not milk constituents have been replaced.
Where milk ingredients do constitute the essential part
For these products, the opportunities for using dairy terms depend on
(i) whether the essential part is expressed in terms of quantity or in terms of characterizing the product; and
(ii) whether non-milk ingredients have replaced milk constituents.
If milk constituents are not replaced and if the milk ingredients constitute the essential
part in terms of quantity, the product is a composite milk product and dairy terms
can be used in accordance with Sections 4.1 to 4.5 of the GSUDT.
If milk ingredients only constitute an essential part in terms of characterizing the
product (for example, cheesecake, butter cookies) dairy terms can be used provided
that it would not be misleading to consumers and provided that the product does not
substitute for a milk product. If the latter is the case (for example, a rice cheese), the
use of dairy terms could be considered to be misleading and is therefore not allowed
other than in the ingredients list.
Where milk constituents are replaced, in whole or in part
For these products, there appear to be no opportunities other than those described in
9.3.1 of this paper, above. Examples or these products are blended fat spreads with
signicant milk fat content, imitations of cheese made with milk protein and vegetable
oil, and coffee whiteners.
14
For these foods (for example, beer, soy drinks) it is not allowed to refer in any form to milk,
a milk product or a composite milk product, unless, the product name with a dairy term
is recognized widely according to long-established usage in the country of retail sale (see
9.2 of this paper).
19 Descriptive designations are designations that in appropriate terms describe the true nature of the food in a
way that is transparent and non-misleading to the consumer. Consequently, descriptive designations should refer
to the raw materials and ingredients used and in the state in which they have been used and, where appropriate,
to the nature of the change(s) imparted to the product and/or to the intended use.
15
Annex 1:
16
4.2.3 Notwithstanding the provisions of Section 4.2.2 of this Standard, milk which is adjusted for fat and/or protein content and which is intended for direct consumption, may
also be named milk provided that:
it is sold only where such adjustment is permitted in the country of retail sale;
the minimum and maximum limits of fat and/or protein content (as the case may be) of
the adjusted milk are specied in the legislation of the country of retail sale. In this case
the protein content shall be within the limits of natural variation within that country;
the adjustment has been performed according to methods permitted by the legislation of
the country of retail sale, and only by the addition and/or withdrawal of milk constituents,
without altering the whey protein to casein ratio; and
the adjustment is declared in accordance with Section 4.2.2 of this standard.
4.3 USE OF THE NAMES OF MILK PRODUCTS IN CODEX COMMODITY STANDARDS
4.3.1 Only a product complying with the provisions in a Codex standard for a milk product
may be named as specied in the Codex standard for the product concerned.
4.3.2 Notwithstanding the provisions of Section 4.3.1of this Standard and Section 4.1.2
of the Codex General Standard for the Labelling of Prepackaged Foods (CODEX STAN 11985, Rev. 1-1991), a milk product may be named as specied in the Codex standard for
the relevant milk product when manufactured from milk, the fat and/or protein content of
which has been adjusted, provided that the compositional criteria in the relevant standard
are met.
4.3.3. Products that are modied through the addition and/or withdrawal of milk constituents may be named with the name of the relevant milk product in association with a clear
description of the modication to which the milk product has been subjected provided that
the essential product characteristics are maintained and that the limits of such compositional modications shall be detailed in the standards concerned as appropriate.
4.4 USE OF TERMS FOR RECONSTITUTED AND RECOMBINED MILK PRODUCTS
Milk and milk products may be named as specied in the Codex Standard for the relevant
milk product when made from recombined or reconstituted milk or from recombination
or reconstitution of milk products in accordance with Section 4.1.2 of the Codex General
Standard for the Labelling of Prepackaged Foods (CODEX STAN 1-1985, Rev. 1-1991), if
the consumer would not be misled or confused.
4.5 USE OF TERMS FOR COMPOSITE MILK PRODUCTS
A product complying with the description in Section 2.3 may be named with the term milk
or the name specied for a milk product as appropriate, provided that a clear description
of the other characterizing ingredient(s) (such as avouring foods, spices, herbs and avours) is given in close proximity to the name.
4.6 USE OF DAIRY TERMS FOR OTHER FOODS
4.6.1 The names referred to in Sections 4.2 to 4.5 may only be used as names or in the
labelling of milk, milk products or composite milk products.
4.6.2 However, the provision in Section 4.6.1 shall not apply to the name of a product the
exact nature of which is clear from traditional usage or when the name is clearly used to
describe a characteristic quality of the non-milk product.
4.6.3 In respect of a product which is not milk, a milk product or a composite milk product,
no label, commercial document, publicity material or any form of point of sale presentation
shall be used which claims, implies or suggests that the product is milk, a milk product or
a composite milk product, or which refers to one or more of these products20.
20 This excludes descriptive names as dened in Section 4.1.1.3 of the General Standard for the Labelling of
Prepackaged Foods (GSLPF) and ingredients lists as dened in Section 4.2.1.2 of the GSLPF providing the
consumer would not be misled.
17
4.6.4 However, with regard to products referred to in Section 4.6.3, which contain milk or a
milk product, or milk constituents, which are an essential part in terms of characterization
of the product, the term milk, or the name of a milk product may be used in the description of the true nature of the product, provided that the constituents not derived from milk
are not intended to take the place, in part or in whole, of any milk constituent. For these
products dairy terms may be used only if the consumer would not be misled.
If however the nal product is intended to substitute milk, a milk product or composite milk
product, dairy terms shall not be used.
For products referred to in Section 4.6.3 which contain milk, or a milk product, or milk constituents, which are not an essential part in terms of characterization of the product, dairy
terms can only be used in the list of ingredients, in accordance with the Codex General
Standard for the Labelling of Prepackaged Foods (CODEX STAN 1-1985, Rev. 1-1991). For
these products dairy terms cannot be used for other purposes.
5. LABELLING OF PREPACKAGED FOODS
Prepackaged milk, milk products and composite milk products shall be labelled in accordance with Section 4 of the Codex General Standard for the Labelling of Prepackaged Foods
(CODEX STAN 1- 1985, Rev. 1-1991), except to the extent otherwise expressly provided in
a specic Codex standard or in Section 4 of this Standard.
18
All tables/gures included in nal document to be sent also in separate Word, Excel or PowerPoint les, in colour format.
Pictures to be sent in tif or eps format (resolution 300 DPI)
References
Example:
Example:
1 Singh, H. & Creamer, L.K. Aggregation & dissociation of milk protein complexes in heated reconstituted skim milks. J. Food Sci.
56:238-246 (1991).
2 Walstra, P. The role of proteins in the stabilization of emulsions. In: G.O. Phillips, D.J. Wedlock & P.A. William (Editors), Gums &
Stabilizers in the Food Industry - 4. IRL Press, Oxford (1988).
Abstracts
An abstract not exceeding 150 words must be provided for each paper/chapter to be published..
Address
Authors & co-authors must indicate their full address (including e-mail address).
Conventions on spelling and editing
IDFs conventions on spelling and editing should be observed. See Annex 1.