The phrase low fat on a package is not a marketing word but a claim whose condition is defined in advance. According to the claim conditions reported by Türkiye Beslenme Rehberi (TÜBER), Türkiye's national dietary guideline, for this phrase to be used the fat in 100 grams of a solid food must be no more than 3 grams, and the fat in 100 milliliters of a liquid food no more than 1.5 grams.
Why is the claim not a free expression?
Its basis is a regulation. Article 11 of the Türk Gıda Kodeksi Beslenme ve Sağlık Beyanları Yönetmeliği (the Turkish Food Codex regulation on nutrition and health claims) says that only the nutrition claims listed in its Annex 1 may appear on the label, in the presentation or in the advertising of foods, and only on condition that they meet their own requirements. That is, writing a phrase that is not on the list onto a package is not free. For a claim to be made, the nutrient the claim is about must also have had its useful nutritional or physiological effect established with generally accepted scientific evidence.
Article 5 of the same regulation counts how the claim may not be used: it cannot be unclear, wrong or misleading; it cannot give rise to doubt about the nutritional adequacy of other foods; and it cannot be built in a way that would support or encourage the excessive consumption of a particular food.
The thresholds on the fat side
Two separate steps are defined for fat. For low or reduced fat the limit is 3 grams in 100 grams and 1.5 grams in 100 milliliters. The fat free claim is much narrower: the fat in 100 grams of solid or 100 milliliters of liquid food cannot exceed 0.5 grams.
Trans fat has its own line. For the contains no trans fat claim, the trans fatty acid amount must be less than 1 gram in 100 grams of total fat, in fats or in foods that contain fat as a component. Also, a ratio such as "so many percent fat free" cannot be written on a product that carries the fat free claim.
The thresholds on the sugar side
There are two steps in sugar as well. For low or reduced sugar the limit of 5 grams in 100 grams of solid food and 2.5 grams in 100 milliliters of liquid food cannot be passed. For the sugar free claim the limit is 0.5 grams in 100 grams of solid or 100 milliliters of liquid.
The third phrase is the one most often confused. The no added sugar claim means that there is no mono- or disaccharide, or any other food, added to the food for sweetening; it does not cover the food's own sugar. Indeed, if sugar is naturally present in the food, the phrase "CONTAINS NATURALLY OCCURRING SUGARS" is placed on the label as well.
At what threshold does the fiber claim start?
On the fiber side there are two steps and both are given with two different measures. To be able to say source of fiber, 100 grams of the food must contain at least 3 grams, or 100 calories at least 1.5 grams, of fiber. For high fiber the same values are doubled: at least 6 grams in 100 grams, or at least 3 grams in 100 calories.
When these thresholds are converted into portions the scale shrinks. In a 30 gram portion of breakfast cereal the source of fiber threshold comes to about 0.9 grams and the high fiber threshold to 1.8 grams. Because the claim is defined over 100 grams, the phrase on the package and the amount that comes to the plate are not the same thing.
"Reduced" compared with what?
The condition for comparative claims is different. For the phrase reduced or less, a fall of at least 30 percent in the energy or nutrient amount compared with a similar product is required. In sodium and salt this ratio is 25 percent. The comparison does not hang in the air either: the difference is stated, and the comparative claim is made for the same amount of food, that is, two products are compared over equal weight.
In a claim made for energy there is an additional condition: which property of the food the fall in the total energy value comes from is stated as well. So "lower in calories" is not a sufficient phrase on its own; where the fall comes from is written.
Where does it turn into a mistake?
The first mistake is taking the claim for a judgment about the whole product. "Low fat" says something only about the fat line; the sugar or the salt of the same product can be high. The second mistake is equating "no added sugar" with "sugar free"; the first looks only at the added sugar, the second at the total sugar.
The third mistake is confusing the 100 gram threshold with the portion amount. Almost all of the claims are defined over 100 grams or 100 milliliters, whereas the amount consumed can be larger or smaller than that. You can compare the real values of foods from the nutrition values table, and follow the daily fat and sugar frame from the fat guide and the added sugar article.