Limitations of the Nutrition Label Calculator

The Nutrition Label Calculator (NLC) is developed by the Centre for Food Safety (CFS) to assist the trade in producing nutrition labels by means of the indirect nutrient analysis* and direct chemical analysis. Both approaches have their benefits and shortcomings in terms of cost, dependency on the availability of appropriate food composition databases (FCDs) and competency of the personnel dealing with the nutrient data etc. When using the NLC to make nutrition labels for pre-packaged food products, the traders shall take note the following limitations of NLC:

  1. The NLC is not linked to any FCD. It is the responsibility of the traders to obtain nutrition information from FCDs of reputable sources and to ensure the data is representative of their products.
  2. The NLC does not provide adjusting factors (e.g. yield factors, retention factors). Thus, users shall have all data (including weight of ingredients and nutrients) adjusted to reflect their product as sold before entering such data into the NLC.
  3. The NLC has some technical limitations, hence, users shall assure the data accuracy at every step while using the NLC:
    1. Data cannot be edited once the users finish Step II ("Enter ingredient(s) and Nutrient Contents");
    2. Data cannot be saved, except for the final nutrition label displayed; and
    3. The 10 user-defined nutrients cannot be verified (e.g., typo error, duplication of nutrients, and convention of the unit).

Users should be aware that given these limitations, which are not exhaustive, the accuracy of the results generated by the NLC is determined by the data entered. The traders are held responsible for the accuracy of information provided on food labels. They should keep documentation of the process of analysis (e.g. laboratory reports, FCDs used, adjusting factors applied) and produce them for scrutiny by CFS when discrepancy of values is found between the label and the test done by CFS.

Risk Assessment Section
November 2009

*Limitations of indirect nutrient analysis can be found in the Technical Guidance Notes on Nutrition Labelling and Nutrition Claims